The late radio-tv icon of my youth, Arthur Gordon Linkletter, really should have done a Tax Court blog. Cases such as Eva M. Zaczek, Docket No. 4667-25S, filed 7/15/26, would furnish daily grist for his mill.

Eva confronts STJ Jennifer E. (“Publius”) Siegel with a single issue to decide, the parties having stiped out everything else. What is “the mathematical calculation of the number that correctly belonged in box 11(d) of petitioner’s 2022 Form 8962, Premium Tax Credit (PTC)”? Order, at p. 1.

Referring to the instructions for said form, STJ Publius Siegel says the number should be zero. Eva said the result should be a positive number. Notwithstanding Eva’s objection, IRS concedes that the correct deficiency should be $900, not the $2418 stated in the SND.

But when IRS’ counsel tenders a stiped decision to Eva, she refuses to sign, claiming her deficiency should be $1763, almost double what IRS claims.

Before shaking your head, reader, consider that “(T)he deficiency stemmed, in part, from transcription errors made by the Internal Revenue Service when processing petitioner’s handwritten tax return for that year. Other portions of the deficiency stemmed from petitioner’s calculation of certain items reported on her return.” Order, at p.1. Apparently Eva eschews electrons, as she neither files electronically nor uses the PDF online fillable forms on http://www.irs.gov.

Moreover, Eva provides many pages of calculations showing how she disagrees with IRS’ numbers, proving she owes more than IRS ultimately claims. So she may, but deficiency does not equal balance due. Section 6211 has the calculation of deficiency, but neither any estimateds paid or certain credits figure in. Tax Court can only recompute deficiencies.

OK, pro ses are often naive, deer-in-the-headlights types, so prone to wander off.

Not Eva.

STJ Publius Siegel finds she is “an accountant with a college degree in that field.” Order, at p. 1.