Terrell Joseph, T. C. Memo. 2026-38, filed 5/5/26, filed for CDP and CAP, and also a couple OICs (hi, Judge Holmes).  Take a look at Judge Rose E. (“Cracklin'”) Jenkins’ summary of the series of errors on both sides (and thank you, Judge, for summarizing; I could never unscrambled this frittata on my own).

“Petitioner certainly did not facilitate the consideration of his case by Appeals by (1) being imprecise about the basis for his dispute of his underlying liabilities on his Form 12153, (2) making off-base complaints about the IRS’s collection actions leading up to the CDP hearing requests, (3) submitting multiple nonprocessable OICs, and (4) ultimately submitting an OIC with an amount untethered from his ability to pay. However, he did (1) suggest to the Second AO that he had not timely received the SNOD that purportedly provided him a prior opportunity to dispute his underlying liabilities for the 2014 through 2016 tax years, (2) provide a full complement of supplemental information, including relevant documentation requested by the Second AO, and (3) consistently maintain understandable disputes of his underlying liabilities and the accounting for his real property in the RCP computation. And although some of petitioner’s disputes were groundless, the administrative record suggests that the Second AO may have disregarded multiple provisions of the IRM and thereby failed to properly (1) determine whether petitioner was entitled to dispute his underlying liabilities, (2) verify that the requirements of any applicable law or administrative procedure were met with respect to the assessments, (3) determine petitioner’s RCP, and (4) evaluate petitioner’s request for an IA. Accordingly, this Court cannot conclude that Appeals did not abuse its discretion. Therefore, this Court will remand the case to Appeals for a supplemental administrative hearing in accordance with this Opinion and for the issuance of a supplemental notice.” T. C. Memo. 2026-38. at p. 26.

Looks like Terrell got his trusty attorney involved to clean up this mess. Nice work sorting this out.