Whether Pliny the Elder or Seneca first said it, the template remains. Ex CLEflogger semper aliquid novi. Today, it’s yet another novelty in the peddler’s pack, and even though they’re on for trial Monday, FBA St. Clair Property C, LLC, Jeffrey L. Smith, Partnership Representative, Docket No. 14406-23, filed 9/12/25, have a motion in limine that’s a real swangdangler.

I’ll turn it over to Judge Elizabeth A. (“Tex”) Copeland. The C-Clairs request “(1) ‘the Court exclude from trial all evidence relating to tax filings of other taxpayers, other entities, and other tax liabilities not before this Court’ and (2) that ‘the Court rule in advance of trial that Respondent is prohibited from introducing evidence related to any property or taxpayer other than [St. Clair C] and FBA St. Clair Property, LLC (‘St. Clair A’).]'” Order, at p. 1.

“This request was made without regard to whether any such evidence might be relevant to the issues presented in this case, such as a donation or valuation of a property adjacent to or in the same County as the subject property.” Order, at p. 1.

I need hardly award a Taishoff “Good Try, Hail Mary Division” to the redoubtable Vivian D. (“Golden”) Hoard, Esq., C-Clair’s trusty attorney. Be there scarcely enough ice to chill a London pub pint (45 F.), and be the sun at zenith, VDH is on the march.

Judge Tax Copeland isn’t having any.

Judge Tex Copeland will seal any taxpayer info that Section 6103(h)(4) doesn’t cover, and publicly available info like recorded deeds, sales contracts, local property tax records, testimony from sellers, and judicially-noticeable 201 FRE stuff go in anyway, unshielded by Section 6103.

Of course, VDH and her trusty and battle-hardened colleagues can object to individual items on 402 and 403 FRE bases, and anything else they can think of, at trial.

Finally, that the C-Clairs stiped to be bound by evidence in a test case doesn’t preclude introducing relevant and probative evidence here or prevent Judge Tex Copeland from blocking any irrelevant or incompetent evidence. While principles and parameters are limiteds to those in the test case, valuation of real property is always a one-off, as every piece of real estate is unique.