Valarie Lindsey, T. C. Memo. 2026-94, filed 9/24/26, completes the four-opinion superfecta the hardlaboring clerks in The Glasshouse on Second Street unleashed upon this blogger who never did them any harm.

Valerie’s trusty attorneys have dissected, sliced, and diced every step of the process from Examination to Appeals to Appeals Processing Support to USPS to prove not only that the SNOD wasn’t mailed, but that it didn’t even exist. I give this dynamic duo a Taishoff “Good Try, Second Class” in the Lost Causes Division.

Judge Courtney D. (“CD”) Jones finds that, despite IRS’ botched record and file keeping, it was and it did.

Cobbling together IRS records (which slide under the hearsay tag via FRE 803(6) business records) there was a SNOD, and the reprint IRS tenders will serve to show it. As for mailing, the PS3817 is admittedly defective, but IRS personnel testimony and certified mail receipt, taken together, establish mailing.

I am reminded of Mark Twain’s famous story of how he and Professor Henry Fairfield Osborn built a brontosaur for New York City’s  Museum of Natural History with nine dinosaur bones and bags of plaster of paris.