Abdelhafid Rahmani, Docket No. 4624-24, filed 4/10/26 entered this country in 1995; since 1996, he has been incarcerated, Order, at p. 1. He claims that since he got the $1400 stimulus credit for tax year 2021, IRS conceded that he entitled to same for tax year 2020, so the deficiency for that year is invalid.

Wrong, says Judge Ronald L. (“Ingenuity”) Buch. IRS’ failure to challenge a position isn’t a concession.

Likewise, Ab’s challenge to IRS and SSA computer transcripts showing he had no valid TIN for work in The Land of the Free cannot surmount the FRE 803(6)(A) and 902(11) “submitted by someone with knowledge” barrier.  Order, at p. 4.

Ab’s year-at-issue return failed to include the valid identification number mandated by Sections 6428(g)(3)(A) and 6428A(g)(4)(A), which define “valid identification number” as a “social security number (as such term is defined in section 24(h)(7)).” Ab has a number, but it’s not valid for US work. Ab does claim he worked for McDonald’s in 1995, but “(T)his bare allegation alone is not sufficient to show there is a genuine dispute as to a material fact. Rule 121(d).” Order, at p. 4.

Summary J for IRS sustaining deficiency.

I must say that in whatever slammer Ab has passed the last thirty (count ’em, thirty) years, there is access to a good law library, or perhaps adept jailhouse lawyers. And whatever Ab’s delictions that landed him there, he has diligently applied himself and chosen good advisors.