Joseph R. Gottesman, T. C. Memo. 2025-94, filed 9/10/25 is living the 1939 hit tune by Michael Carr and Jimmy Kennedy. Joseph R. Gottesman (that’s Doc Gottesman, MD, hereinafter sometimes “Doc G”) is south of the Border, down Mexico way, because there’s an active arrest warrant awaiting him in Phoenix, AZ, where he requested trial. Doc G listed Laredo, TX as his mailing address, although he resides in Jalisco.

Judge Courtney D. (“CD”) Jones spends a whole footnote sorting out where to lay venue for Doc G’s appeal, and finally ends up with DC Cir, the Section 7482(b)(1) flush language default. But Taishoff is prepared to bet Judge CD Jones one of his own self-made special pineapple jalapeño Margaritas against a warm bottle of Modelò Negra that Doc G appeals nothing.

Doc G has plenty of badges of fraud to merit the thoroughly Boss Hossed Section 6663 fraud chops IRS wants to add to the SND (which Judge CD Jones calls a “NOD,” which is confusing; a Notice of Determination, e.g., from a CDP or an innocent spousery, is properly shortened to “NOD.” A Section 6212 statutory notice of deficiency is a “SND.”). The deficiency is north of $300K, T. C. Memo. 2025-94, at p. 6.

The rap on Doc G is one count of Section 7201 criminal tax evasion. Doc G moves for an indefinite stay of all proceedings until his criminal case is heard. But he won’t go to Phoeniz, AZ for fear of arrest. While Fifth Amendment concerns may be valid, there is no blanket exemption. Each question in discovery or the trial stands on its own.

“In the Motion to Stay, he states that he fears arrest if he appears in the District of Arizona. Of note, Dr. Gottesman has not represented that he will now or at any time in the near future appear to face criminal charges or work to resolve his criminal case. Thus, it appears that he is abusing this Court’s process by seeking an indefinite stay while he avoids prosecution in the criminal case.” T. C. Memo. 2025-94, at p.14.

Ya gotta say Doc G has a set of high-carbon chromium alloys.

But Judge CD Jones isn’t wearing any Margaret Atwood red hat. “This Court will not be a handmaiden to such tactics.” T. C. Memo. 2025-94, at p 13.

Summary J to IRS for deficiency and chops. No stay for Doc G; show for trial or default.