Though I very much doubt they read this my blog, I do hope Neuse River Council of Governments, Docket No. 8194-25L, filed 11/3/26, followed my advice in my blogpost “Wagner Boechlerized,” 1/7/26.

Back then I counseled petitioners “if seeking withdrawal without prejudice in a CDP, take a good hard look before relying on Dunn.”

The Neuse Councilors do seek to withdraw, claiming that “they reached an agreement with the Internal Revenue Service –  Internal Revenue Service Independent Office of Appeals.” Order, at p. 1.

And IRS certainly agrees.

Now I don’t want to play the part of the 2% indirect partner in a Dixieland Boondockery who tries to blow up a settlement with an after-the-whistle intervention attempt.

But I do hope the Neuse Councilors did take that good hard look. And if they did and are still happy, why not move for Entry of Stipulated Decision.