No, not a law firm, rather the Scylla and Charybdis whereupon founder Section 7623 whistleblower discovery demands. STJ Diana L. (“Sidewalks of New York”) Leyden drives home again the ironclad record rule limitations in Joshua L. Gottlieb, Docket No. 23996-18W, filed 9/12/25.

Josh’s trusty attorney, whom I’ll call Scott, wants to supplement the administrative record “with documents in connection with the examination performed by IRS employees and communications between those employees and an IRS criminal investigation division special agent. Petitioner has not proffered any such documents. To the extent the Court can construe petitioner’s Motion to Supplement the Administrative Record as a request for discovery, that relief is typically not available in administrative record cases, such as this one. See Berenblatt, 160 T.C. at 534. The Court has held that the administrative record filed by respondent enjoys a presumption of correctness absent clear evidence to the contrary. Berenblatt, 160 T.C. at 534. There exists a narrow exception to this presumption if the party moving to compel discovery makes a significant showing that it will find material in the WBO’s possession indicative of bad faith or an incomplete record.” Order, at p. 4.

Scott has neither documents nor anything to show bad faith, at least not enough to pass muster with STJ Di.

IRS’ paperwork, though not of the best, shows that they knew about some of what Josh claims four (count ’em, four) years before Josh blew, was already auditing some at the time, and on the rest took no action.  Order, at p. 2.