Merriam-Webster, the ultimate chaw-source, says the phrase first hereinabove written at the head hereof (as my deliberating-the-tip-amount on their two Grey Gibson lunch check colleagues would say), opines said phrase is “British, old-fashioned,” but C. Crow Collateral Corporation is still seeking sealing of their third-party subpoena responses in Nat S. Harty & April D. Harty, Docket No. 23354-21, filed 12/2/25.

And having no better luck than they had in Richard B. Stillahn & Lisa R. Lang Stillahn a year ago; see my blogpost “Even If You Don’t,” 12/20/24. Btw, appeal was taken to 9 Cir back in January.

The Crow seems to have no better luck with ex-Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan’s now than it did back then.

Section 6103(h)(4)(C) strikes again. “… section 6103(h)(4)(C) provides there is an exception ‘if such return or return information directly relates to a transactional relationship between a person who is a party to the proceeding and the taxpayer [whose information is to be disclosed] which directly affects the resolution of an issue in the proceeding.’ This exception allows information about a transactional relationship with a third-party taxpayer to be disclosed if that information has a direct bearing on the outcome of an issue in a case.” Order, at p. 2.

“Here, SCCC was the facilitator of a transaction entered into by petitioner. The dealing of petitioner and SCC were intertwined. There is no requirement that the transactional relationship require a bilateral contract between the third-party and the petitioners. To decide this case, the Court will look at the interrelated transactions that made up the transaction at issue. Accordingly, the Court will deny SCCC’s motion to seal. In a separate order, the Court will unseal documents to be consistent with this Order.” Order, at p. 2.