That’s how IRS answered all but eight (count ’em, eight) of the 128 (count ’em…don’t bother, Judge James S. (“Big Jim”) Halpern already did it for ya) admissions sought by the trusty attorneys for Beveled Edge Insurance Company, Inc., et al., T. C. Memo. 2026-57, filed 7/20/26, in their Third Request for Admissions. 

To clear things up, it’s well known that I loved requests for admissions in my practicing law days. It was cheap discovery. But 128 on the third go-round? As Groucho Marx said, “I love my cigar, but I take it out once in a while.” And my watchword has been: “Any lawyer who can’t find an ambiguity should find another way to make a living.” But there’s good-faith deep-diving analyzing and defusing IEDs and knuckleballs, and then there’s obstructionist semantic snivel-drivel.

Judge Big Jim is far too well-bred to suggest IRS counsel is engaging in any base doings, but he does tell them to hew to Rule 90, admit, deny, coordinate with adversary if you’re unclear what they want, and object to form only if you’ve first answered or exhausted all avenues of relief. And break up compound questions, admitting or denying each branch so far as reasonably possible. And don’t quibble about documents; you can admit to a true copy or an original without admitting that it’s either admissible or that its contents are true.

The Beveler’s trusty attorneys want everything deemed admitted and IRS sanctioned, but that’s not happening.

A quick word to Ch J. Patrick J. (“Scholar Pat”) Urda: I see there’s still a chance to comment on Your Honor’s proposed Rule changes. May I propose an amendment to Rule 33, or even a new rule for motions? Every motion paper must be signed to Rule 33(b) standards. Meritless requests for sanctions should be themselves sanctionable. Even FRCP 11(d) is deficient in this respect.