The late Andy Warhol’s signature comment (which he didn’t say in the words often misquoted) is expanded by Judge Christian N. (“Speedy”) Weiler in Longwood Preserve Holdings, LLC, Longwood Preserve Investors, LLC, Tax Matters Partner, Docket No. 12421-19, filed 10/27/25. IRS wants trial testimony from individual syndicatees in this Dixieland Boondockery, to which said syndicatees object.

The syndicatees claim they have no personal knowledge as to the qualifications of appraisers VS & W or the adequacy of their appraisal. VS & W, for those who tuned in late, are regulars on the Dixieland Boondockery circuit. But IRS may want more from them than what they don’t know about Messrs. VS & W.

“Although petitioner presents declarations from the subpoenaed individuals, which indicates they lack personal knowledge with respect to the original appraisal and appraisers involved in the conservation easement donation; we anticipate respondent intends to call these individuals for other reasons, namely introduction of emails and other communications that they each had as potential investors in petitioner and the conservation easement at issue.” Order, at p. 6.

But requiring the five (count ’em, five) individuals to show up and sit through the trial is a bit much for Judge Speedy Weiler, so he limits their burdens.”… we will require their attendance at trial from each of the nonparties; however (to lighten the costs and inconvenience to everyone involved) we will permit the testifying individual to appear at a date and time certain of their choice during the week of November 10, 2025 having the choice to appear in person or virtually (by ZoomGov) and imposing a time limit of two hours on the testimony of each individual, with up to sixty minutes allocated to each party.” Order, at p. 6.

Judge Speedy Weiler does quash IRS’ trial subpoena to a local realtor with no connection to the deal or the parties. Looks like IRS wants an unpaid expert rebuttal witness.

There a lot of argy-bargy about introducing public land records (Order, at pp. 3-4), which I leave to specialists, but the records go in. The authentication declaration by a local court official, and a spreadsheet prepared by a local government appraiser, are put on hold. Word to IRS: better subpoena the people for trial.