Lance Stevens, T. C. Sum. Op. 2026-10, filed 11/2/26, “…focused on asserting, without elaboration, that his rights were violated, that he was never notified that he needed to provide documentation about his expenses, and that he never received any letters or notices from the IRS asking for substantiating documentation. Although the Court understands petitioner’s frustration with the process involved in the audit for his [year at issue] federal income tax return and his case before the Court, he did not meet his burden of proof with respect to his claimed deductions under either rule; therefore, the Court finds for respondent on this issue.” T. C. Sum. Op. 2026-10, at p. 8.

Worse, by establishing the gross receipts of his business were greater than what IRS claimed in the SND, Mr. Stevens gave IRS a free kick to increase the deficiency.

STJ Diana L. (“Sidewalks of New York”) Leyden doesn’t mention whether  anyone sought the assistance of a calendar call commando, but this seems like a perfect opportunity for an intervention.