Tax Court has blown off the Jarkesy-based challenges to the Section 6662 variety chops on the public rights principle (see my blogpost “Full House,” 8/21/25), but Section 6663 fraud chops come a lot closer to the “commonlaw equivalent” than classic revenue collection.

Howbeit, Judge Albert G. (“Scholar Al”) Lauber won’t swing at that curveball. He says it’s too late when it’s first raised in a brief accompanying a Rule 155 beancount. It was neither raised on the trial nor in the two (count ’em, two) post-trial briefs.

Rule 155 beancounts are no place to raise new legal arguments.

So Vincent Fumo, Docket No. 17603-13, filed 1/14/26, is mulcted for the agreed-upon deficiencies and the 75% chops.

Taishoff says I get the strong feeling that, as Mary Queen of Scots used to say, “my end is my beginning.” More to come on this one.