Hommel v. Commissioner T.C. Memo. 2020-4
On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion. The real issue, however, was how close Judge Holmes could get to calling the petitioner a #^&%$ idiot without actually doing so. Personal Note in Hommel v. Commissioner – When I Grow Up, I Want to be Like Judge Holmes Rarely are we given an opinion where the sarcasm isn’t veiled, where the puns aren’t scrapped for platitudes, where the passive aggression is not tamed if not wholly eliminated, and where the Judge doesn’t even attempt to hide his utter scorn for a litigant whose sheer incompetence landed him in the quagmire that he now finds himself mired in. Judge Holmes’…
