Bernard J. Donachie, coaming late to the party in Smith Mill Rock, LLC, Mulhern Jasper Exploration, LLC, Tax Matters Partner, Docket No. 13132-22. filed 6/8/26, says “there are ‘active watchdog investigations’ into the IRS appraiser who worked on the case during the examination and ‘significant procedural deficiencies regarding the Government’s expert valuation.’” Order, at p. 2.

It’s another stiped-out Dixieland Boondockery, wherein none of the partners save the TMP participated in litigation or settlement, until Bernie comes in during the 60-day Rule 248(b) nonparticipant last chance, brandishing his 2.2759232% interest in Mulhern Jasper, which makes him an indirect partner in Smith Mill Rock.

Judge Travis A. (“Tag”) Greaves is willing to look and see if Bernie has a clear and convincing reason why he’s late and that he has something to show the settlement isn’t reasonable.

Spoiler alert: He doesn’t and he doesn’t.

It took Bernie a year-and-a-half to figure out he was sent the wrong appraisal. And he got a bunch e-mails (hi, Judge Holmes), even though he claims he didn’t get some (everybody else did). And yeah, he’ll have some tax to pay, but that’s what happens when you take a minuscule interest in a deal with someone else’s finger on the button.Ultimately, whatever happened at Exam with the watchdog, the past isn’t even prologue as deficiency trials are de novo.