Judge Mark V. (“Vittorio Emanuele”) Holmes disrespects not a single partitive genitive, but tramples, upends, and deconstructs both IRS’ bank account reconstructions and petitioner’s implausible testimony and uncooperative behavior, in Hank Risan, et al., T. C. Memo. 2026-78, filed 9/2/26.

Hank is a self-styled Renaissance man indicted for fraud. T. C. 2026-78, at p. 4, footnote 5. But IRS doesn’t allege fraud here. IRS has troubles enough, with computational fumbles at exam and an unsupported alter ego argument. Unreported income allegations are washed away. And while Mark’s testimony draws a large bill on credulity, his trusty attorney points out enough to let BoP sink a lot of IRS’ case.

What will be left for the Rule 155 beancount to sort and what the final deficiency will be is a real head-spinner.