Two (count ’em, two) gifts that keep on giving, Raju J. Mukhi, Docket No. 4329-22L, filed 10/5/26, making his fifth appearance in this my blog, and Section 6751(b) Boss Hossery, that hardy perennial, meet before Judge Christian N. (“Speedy”) Weiler.

Raju is fighting about Appeals’ verification that Exam properly Boss Hossed the chops bestowed upon him, and whether the RA at Exam had indeed done so. “We see these as two separate issues.” Order, at p. 2. Note the RA may have done it right, but the AO may have blown verification.

Raju’s trusted (and trusty) advocates and litigators object to IRS’ motion to remand to Appeals, claiming it will delay the January trial.

Isn’t remand supposed to give the taxpayer a chance to fill in whatever was left out the first time around, and to supplement the record for judicial review?

Yss, but.

“Generally, we remand a case to the Appeals Office when a taxpayer did not receive a proper hearing, and the new hearing is necessary or will be productive. The resulting section 6330 hearing on remand is not a new hearing, but rather ‘provides the parties with the opportunity to complete the initial section 6330 hearing while preserving the taxpayer’s right to receive judicial review of the ultimate administrative determination.’. As noted earlier, we have remanded a case to the Appeals Office to clarify the record regarding an officer’s determination that a notice of deficiency was properly mailed.” Order, at p. 2. (Citations omitted).

Nevertheless, Judge Speedy Weiler, true to his cognomen, tells the parties to get ‘er done before the trial date.