I don’t want to spend nearly the amount of time that Judge Rose E. (“Cracklin'”) Jenkins had to spend on Mohammad Fawad Aryanpure and Malika Aryanpure, T. C. Memo. 2026-48, filed 6/10/26. Doc Mo and Doc Mal ran drive-up medical clinics of the urgent care variety. These are cash-on-the-barrelhead or active credit card operations. Doc Mo was skimming cash, depositing the day’s green one-for-you, one-for-me.

Unfortunately, trusty CPA was too trusting, disclaiming any auditory function and taking Doc Mo’s numbers at face value. Judge Cracklin’ Jenkins doesn’t buy Mo’s testimony. 

Doc Mal gets off the Section 6663 fraud chops, but Doc Mo goes down for all four (count ’em, four) years at issue. But both owe the deficiencies, as the returns were fraudulent and SOL is out for fraud.