Eric Maurice Pinckney, T. C. Memo.2026-113, filed 11/4/26, has a five (count ’em, five) day chance to cut down his deficiencies and fraud chops. He gets some minor reductions, but the heavy-duty deficiencies remain, as do the fraud chops.

Judge Morrison has a lengthy review of when a civil audit becomes the basis of a criminal case. Pinckney has major problems of proof, probably because IRS seized his records for the criminal trial in USDCDSC, in consequence of which Pinckney pled out to a criminal conspiracy count.

Judge Morrison shows why this opinion issued four (count ’em, four) years after trial. There are years of bank account reconstruction. Pinckney was self-represented. The result was predictable.