No, not Oliver Stone’s 1986 war story; rather I am referring to Paul Dietzel’s pioneering LSU aggregations, The White Team, The Go Team, and The Chinese Bandits. We cardcarrying Medicare members remember their counterparts’ appearances in the 1962 Army-Navy game, with the hats and raucous cheers. Gone, alas, like our youth, too soon.

When OCC tries this move on the eve of trial in Habitat Green Investments, LLC, MM Bulldawg Tax Matters Partner, et al. , Docket No. 14433-17, filed 12/19/25, the Habs claim illegal substitution.

“…petitioner filed an Objection to respondent’s Motion to Withdraw Longstanding Trial Counsel Shortly Before Trial (Objection). In the Objection, petitioner states how ‘[r]espondent’s newly entered counsel’s failure to identify any reason for withdrawal, let alone good cause, is sufficient to deny his Motion.’ The Objection goes on to state how ‘allowing respondent’s main trial counsel to withdraw would materially harm petitioners, would violate the Court’s Rules and prior precedent, and would unnecessarily increase the cost of litigation in this, and the companion case St. Andrews.” Order, at p. 1.

Judge Christian N.(“Speedy”) Weiler brushes this aside.

Rule 24 governs, not 5 Cir learning. Besides, it’s not that IRS is without counsel. It recently filed EoAs for the new batch and they haven’t asked for timeouts. “While petitioner points to other proceedings with newly enrolled counsel as evidence of their assertions, in these consolidated cases we determine petitioner’s allegations raised in their Objection to be wholly unfounded.” Order, at p. 6.

Will petitioners seek Section 6673(a)(2) sanctions against the new arrivals?