When we hear our equivalent, the reflex takes over; one hand grabbing for the steel pot, the other trying to one-hand one’s way into the flopping flak jacket, the mind trying to remember where we put that extra box of 7.62 FMJ ball. “You are the third lawyer I’ve consulted, and the other two are morons.” Get ready for a big-time firefight, and the enemy isn’t the only one shooting at you.

Judge Cary Douglas (“C-Doug”) Pugh tosses Michael V. Kervin’s and Stacie L. Kervin’s three (count ’em, three) conjoined cases (Docket Nos. 22378-22, 10249-23, and 482-24) for want of prosecution.

Judges Travis A. (“Tag”) Greaves and Benjamin A. (“Trey”) Guider III both folded when confronted by plaintive tales of illness, natural disasters, and requests for yet further continuances.

Finally, Judge C-Doug Pugh has had it. IRS asked for an OSC, and Judge C-Doug Pugh granted it, telling Mike and Stacie to show specific documents they would put in on the trial to substantiate income and deductions.

” Petitioners’ response… failed to do any of this. Rather, it stated that petitioners needed additional time to respond. And it stated that as a show of good faith and concrete progress petitioners had hired a new tax preparation firm to review and correct their 2018 and 2019 returns (if necessary) and prepare returns for 2020 through 2025. Petitioners also cited their newly hired tax preparation firm as a basis for their… Motion for Continuance… which we denied…. Hiring a tax professional may be an important step in bringing petitioners into compliance with their federal tax obligations but it does not address the issues in the pending cases—namely, what evidence they would offer at trial to support their claimed income and deductions. Their repeated nonresponses affirm the Court’s conclusion that they do not intend to provide any evidence of their income and deductions but rather seek only to delay the inevitable.” Order, at pp. 1-2.

Judges, counsel, and preparers, it’s all the same story. When you’re the third, look out.