The 1931 Harry Barris – Gordon Clifford classic that catapulted Bing Crosby to all-time greatness echoes through the unending barrage of IRS’ partial summary J motions to assure Boss Hossery in the Dixieland Boondockery scuffles.

Just one example: Harviell Lowlands, LLC, Harviell Lowlands Investments, LLC, Partnership Representative, Docket No. 5750-23, filed 9/26/25.

Judge Jeffrey S. (“Schwer”) Arbeit has this one.

“…petitioner filed notice of concession in response to respondent’s motion for partial summary judgment… maintaining that respondent addressed the issue of whether he has demonstrated compliance with the written supervisory approval requirements under Internal Revenue Code (‘I.R.C.’) § 6751(b) for the following penalties identified in the Notice of Final Partnership Adjustment issued to Harviell Lowlands, LLC: I.R.C. §§ 6662(c), 6662(d), 6662(h), 6662A.” Order, at p. 1.

Among Harviell’s trusty attorneys I note a constant reader of this my blog, who has decided not to fight a losing battle by trying to enforce Congress’ miserably-drafted attempt to protect taxpayers from bludgeoning by over-zealous RAs against a judicial system that has systematically gutted whatever minuscule force it was intended to have.