To quote the Man from Mumbai, “by the laws of the family circle, ’tis written in letters of brass” that there can be no denial or diminution of a charitable deduction without an IRS motion for Boss Hossery summary J. So even when pointed dissents follow a denial of summary J all around in The David and Barbara Green 1993 Dynasty Trust, Mart D. Green, Trustee, et al., T. C. Memo. 2025-100, filed 10/2/25, there comes Judge Emin (“Eminent”) Toro to award IRS summary J in the usual barrelshoot.

The issue is the Notice of Partnership Adjustment at Exam. The Dynasts claim the electronic signature thereon doesn’t satisfy Boss Hossery. But this is preliminary, doesn’t show Exam is finished. Judge Eminent Toro goes through the 30-day Letter liturgy.

Taishoff says the bludgeoning the statute was supposed to prevent always takes place “preliminarily.”

That a workpaper from IRS shown to the Dynasts doesn’t name them, but the Sub S corporation in which they hold stock, doesn’t matter, as Reg. Section 1.6662-5(h) says initial penalties go to the entity first, even if later passed through to the shareholders.

And while the NOPA is supposed to state penalties separately for each item, that footfault doesn’t invalidate the notice; the parties will fight out the computations on the trial.