Computer Sciences Corporation, 165 T. C. 8, filed 10/6/25, says RA Supe G. didn’t do it when RA H suggested a five-and-ten 20% chop, but Judge Albert G. (“Scholar Al”) Lauber says Boss Hossery is an essential part of any deficiency case where chops are invoked, not a stand-alone, so the Puters have plenty chances (hi, Judge Holmes) to make their case for reasonable cause.

The Puters did a Section 368(c) shuck-and-jive with Bank of Tokyo-Mitsubishi UFJ that generated a $651 million capital loss, which IRS blew up. Dropping the Section 6662(a) negligence chop four years into the program, IRS stuck with the five-and-ten 20% understatement chop, on which RA Supe G signed off four (count ’em, four) times during the four years this rattled around between Exam and Appeals.

It’s old home week for Boss Hoss caselaw going back to Chai and Graev. How could you have a Boss Hoss faceoff without Belair, Kroner, Raifman, Palmolive, and a ride on Laidlaw’s Harley Davidson?

I’ve blogged ’em all. Pore l’il ol’ 5 USC §706(a)(2) hasn’t got a prayer.

The Puters collapse in this Hebrews 12:1 barrage.

I’ll save ya my usual rant on this statutory disaster.