Two petitioners who’ve been here before are back, but unlike Ol’ Blue Eyes, these fare no better the second time around.

First, Albert S.N. Hee and Wendy R. Hee, T. C. Memo. 2026-53, filed 6/23/26. It’s Al’s story, all about constructive dividends from Al’s telephone C Corp and subsidiaries that paid for his kids’ education, a couple trips to exotic locations (hi, Judge Holmes), a million-dollar house near his kids’ college, and a $1246 sport coat from Saks Fifth. Judge Christian N. (“Speedy”) Weiler is all over that sport coat. Judge, so am I.

“Mr. Hee was invited to dinner with executives from Raytheon by his longtime college friend and business colleague, TP. Shortly before dinner Mr. Hee purchased a sport coat from Saks Fifth Avenue for $1,246 which he wore to the dinner. The cost of the sport coat was deducted by [C Corp] as an office expense at the direction of Mr. Hee.” T. C. Memo. 2026-53, at p. 11. (Name omitted). Doesn’t make the Section 162 ordinary-and-necessary cut, because you could wear it in the street.

All Al’s written-off largesse to self and family get shot down, with fraud chops at no extra charge. 

Charlton C. Tooke, III, T. C. Memo. 2026-54, filed 6/23/26, last here on Constitutional grounds (see my blogpost “Scrapbook, 1/29/25,” filed 1/29/25), now finds his OIC and PPIA bounced. His and former spouse’s medical problems and his current special-needs adoptee’s don’t impair Charlton’s ability to pony up the self-assesseds he owes. Giving $400K to a drug-addicted spouse, while Judge Courtney D. (“CD”) Jones doesn’t expressly say so, might could be maybe so dissipated assets.