No, he isn’t a partner other than the TMP who wants a last-minute intervention in IMCO Services Inc, Docket No. 7090-25L, filed 6/26/26; he was a Greek historian and Roman senator who died about 1800 years before Rule 248(b)(4) was promulgated. He appears in this my blog to highlight the extraordinary erudition of the Tax Court bench, specifically Judge Ronald L. (“Ingenuity”) Buch, who explores the cutting of the Gordian knot as described by the late Arrian, and decides to pull the pin on the “flurry” of motions more particularly bounded and described in Order, at pp. 3-4, and their pendant replies, responses, and supporting documentation.

Ol’ Arrian’s story shows up in a footnote, Order, at p.1, footnote 1.

While the barrage and counterbarrage is going on, IMCO pays up.

A couple motions (hi, Judge Holmes) follow because IRS can’t confirm that IMCO in fact paid up, but ultimately Judge Ingenuity Buch is convinced that they did, invoking poor ol’ Jen Zuch to toss the petition for want of jurisdiction: no outstanding debt, no pending lien or levy, nothing for Tax Court to review.  IMCO wants to fight about interest during the COVID hiatus, but that’s been paid along with everything else.

Scholars Al and Pat have a worthy colleague in Judge Ingenuity Buch.