Michael D. Brown, T. C. Memo. 2025-126, filed 12/4/25, irrepressible, claims he now really lives in TX, no longer in NV when 9 Cir. shot down his appeal from 158 T. C. 9, filed 6/23/22, because IRS held his OIC for 27 months, making it automatically accepted per Section 7122(f). You’ll find the backstory in my blogpost “High-Flying Blogfodder,” of even date therewith, as my expensive colleagues would say.

Mike argues collateral estoppel doesn’t apply when he makes the same argument now.

Negatory, says Judge Morrison.

“The sole remaining issue is whether ‘petitioner’s offer in compromise was accepted by operation of I.R.C. § 7122(f).’ We agree with respondent that the Tax Court opinion in Brown, 158 T.C. 187, has resolved the identical issue.  Petitioner has provided no compelling reason to depart from\ that precedent. We therefore hold that the April 19, 2018, offer-in-compromise was not accepted by operation of section 7122(f). Our holding does not depend on any disputed facts.” T. C. Memo. 2025-126, at p. 6. (Citation omitted).

But IRS doesn’t get summary J. If Mike wants to appeal this decision, where does he go? TX is 5 Cir, NV is 9 Cir. So let the parties argue where Mike resided when he petitioned.

Fasten your seatbelts; the flight continues.