I cannot think many, if any, of my readers are hanging breathless on the outcome of the trial in Lola Marie Hussey, Docket No. 5981-24L, filed 2/11/26. Few, again if any, will remember STJ Lewis (“Whatever Shall I Do When He Retires?”) Carluzzo’s rejection of IRS’ summary J motion for confirmation of Appeals’ NOD, so, if you care, check out my blogpost “Milk Run,” 11/26/25 for the scanty backstory.

STJ Lew has two (count ’em, two) questions to resolve, even though Lola Marie thoroughly defaulted (no briefs, no appearance). Was what Lola Marie filed a “return” within the meaning of Section 6702? And was the issuance of the NOD ustaining the collection process an abuse of discretion? Yes and no.

Yes, it was a return, but it was an “all-seros.” She also claims Section 6702 is unconstitutional, but provides no argument in support.

Yes, the chops were Boss Hossed, and Lola Marie’s insistence at the CDP that only liability should be considered is a nonstarter. Anyway, “(B)ecause petitioner refused to have such issues considered at the administrative hearing, we will not consider her challenge to the process here. But if we did, we would find that respondent’s evidence shows that in all respects respondent proceeded as required by section 6320 and section 6330.” Transcript, at p. 8.

This blogpost appears as a matter of record. I can find better subjects for this blog; I don’t want to be accused of milking the milk run.