That’s Intan N. Ismail & Mohd Razi Abd Rahim, Docket No. 15704-24, filed 12/1/25. To be Einstinian, one must do the same thing over again, expecting a different result, and that sums up In & Mohd. It’s a replay of the busted Maylasian deemed C corps that never filed Form 8832 Entity Classification Election, or Form 8858 Information Return of U.S. Persons With Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs), or a Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. Hence no passthrough of deductions.

I got Form 5471 wrong on the Special Enrollment Examination for EA, and it rankles me whenever I see that Form.

Judge Ronald L. (“Ingenuity”) Buch needs none of his vaunted ingenuity here, as Judge Paris already told the story three (count ’em, three) years ago. See my blogpost “Billy Occam, Thou Should’st Be Living  At This Hour,” 11/29/22.

In & Mohd get penalties without even Boss Hossery, as ignoring a case you already lost is clearly negligence or disregard. IRS need provide Boss Hossery only when assessment swims into its ken, because 8. Cir, whence In & Mohd are Golsenized, only cares about Boss Hossery when tax and penalties are assessed, and that hasn’t happened yet.