On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty v. Commissioner was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained. A Lesson in Etoty v. Commissioner to Judge Lauber on When “Less is More” Should be Ignored Petitioner filed a timely Federal income tax return for 2008. Because of insufficient withholding, her return showed a balance due, which she failed to pay. Ugh, another easy CDP case to summarize. I’m on my fifth one this evening. Then Judge Lauber just drops the following sentence into the opinion without another thought: “Petitioner was incarcerated from 2009-2015; upon her release her poor health prevented her from resuming her previous work as a docketing clerk.” Wait. What? Judge Lauber packs so much into that sentence, and…