Attorney-at-Law

DOING THE SAME THING AND EXPECTING A DIFFERENT RESULT

Vincent M. Lorusso, Docket No. 15335-15L, filed 8/11/16, a designated hitter off the bat of STJ Lewis (“A Name That Resounds”) Carluzzo, is yet another example of the famous remark attributed (without much foundation) to Albert Einstein.

IRS gave Vincent M. a NITL, and Appeals affirmed, noting Vincent M. was behind on his current tax payments. He also hadn’t paid his self-assessed 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012 and 2013 Federal income tax liabilities. Hence no installment agreement, and the NITL.

Vincent M. says that’s an abuse of discretion. IRS says no, it’s not.

STJ Lew: “Petitioner’s outstanding Federal income tax liabilities for 2003 and 2004 were the subject of proceeding similar to this one in docket number 9750-15 L. But for the years, the circumstances and positions of the parties in docket number 9750-15 L are identical to the circumstances and positions of the parties in this case.” Order, at pp. 2-3.

And the order and decision in the earlier case state the reasons why Vincent M. loses this time, as he did last time.

Q.E.D.

 

 

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