Judge Albert G. (“Scholar Al”) explores the geography, physiography, demography, and taxability of Emanuel County, GA. And no, I don’t know where that is, either. Scholar Al says it’s in the southeastern part of GA, halfway between Macon and Savannah.

The Emanuel County website asserts it’s friendly. Judge Scholar Al says the HBU of most of it is “for low-density, single-family residences, with agriculture, recreation, and timber harvesting as complementary uses.” Watson Lake Investments, LLC, Terry J. Heath, Tax Matters Partner, T. C. Memo. 2026-106, at p. 2.

Needless to say, Terry and Co. see this as ” mixed-use development, supposedly including 66 to 69 single-family lots, 35 to 45 acres of multifamily and senior housing, and numerous commercial and office sites.” Idem, as my expensive colleagues would say. Judge Scholar Al says “(T)hese back-of-the-envelope development schemes were wholly unrealistic in a rural county with a total population of roughly 22,000.” Idem.

There’s captive 501(c)(3), a turnkey promoter, the usual cloud of witnesses, numbers from Heaven (or the other place) and all the makings of a classic Dixieland Boondockery.

But wait, there’s more!

“As shown on the map, a single-runway airstrip lies directly across a local road to the south of the Watson Lake Property. A state prison lies about 500 yards north of the Property, and a low-income housing project lies less than a mile to the east. The 144-acre tract includes a lake and related flood plain, and roughly 25% of the Property is occasionally or frequently flooded.” T. C. Memo. 2026-106, at p. 6.

Why IRS needed five (count ’em, five) lawyers for this is a puzzlement. Deficiencies and chops sustained.

I have noted petitioners’ counsel before in other contexts. This is, he says, his second full trial in Tax Court. I hope he learns from experience.