I’m sure neither party to Estate of Randy M. Harrigan, Deceased, Kyle Harrigan, Executor, Docket No. 7245-25S, filed 6/3/26, is so ill-bred as to add the adjective that Alfonso Bedoya never said in the most-misquoted sentence from that 1948 classic. And Ch J Patrick J. (“Scholar Pat”) Urda would never think of saying such a thing.

But he does seek to toss Kyle’s petition, because although Kyle was duly appointed ex’r of Randy’s estate, he was disappointed less than a year later. Hence when Kyle petitioned after he was disappointed, there was no one with authority to petition.

So Ch J Scholar Pat tosses the Proposed Stipulated Decision that Kyle and IRS hammered out. And he orders the parties to show cause why the whole case shouldn’t be tossed for want of jurisdiction.

OK, so far no biggie; there are dozens of cases like this.

Except.

Ch J Scholar Pat offers the parties an out.

“The Court notes that, although it appears that we lack jurisdiction of this case, the parties are free to enter into an administrative resolution in accordance with the terms set forth in the above-referenced Proposed Stipulated Decision.” Order, at p. 1.

Taishoff says that’s well and good, but if disappointed Kyle has no authority to represent the estate in Tax Court, what authority has he to enter into any enforceable resolution on behalf of the estate with anyone anywhere?

No, not the hedge fundie’s rake-off. Judge Emin (“Eminent”) Toro has mortgage interest to deal with in Henry O. Igboke & Clara Igboke, Docket No. 12275-24, filed 6/3/26, in an off-the-bencher. Henry & Clara had some mortgage woes in a prior year, from which they refinanced out, paying accrued interest with proceeds from the new loan.

But apparently the accrued interest, though Section163(h) qualified residence interest, was too much to deduct against that year’s income, so Henry claims the overage in year-at- issue.

First problem: the IRC doesn’t allow that.

Second problem: Henry  “…has been a certified public accountant for more than 30 years and regularly prepares tax returns for his clients. He knows how the federal income tax rules work, including those for the home mortgage interest deduction.” Transcript, at p. 4.

Third problem: On the trial, Henry proffers two documents to substantiate his deduction, namely, a substitute Form 1098 and a letter from the servicer of the old mortgage which Henry & Clara refinanced in the prior year. But “[prior mortgage servicer]’s recordkeeper could not find copies of either document in [prior mortgage servicer]’s records. Even more troubling, the alleged Substitute Form 1098 for [year-at-issue] appears to be an altered photocopy of the [prior year] Form 1098 from [prior mortgage servicer]. All the numbers on the purported [year-at-issue] form are identical to those from [prior year], including the interest paid and loan balance. But, on the purported [year-at-issue] form, the [prior] year has been replaced with [year-at-issue], and there appear to be irregular photocopier markings around the year. An [prior servicer] legend has been added at the top of the form, along with a banner that reads ‘Mortgage Interest Statement – Substitute Form 1098.’

“Further, the … letter that [prior servicer] allegedly sent the Igbokes is inconsistent with the Igbokes’ claimed deduction for [year-at-issue]. If the Igbokes had paid $31,635 in interest to [prior servicer] for [year-at-issue in addition to the $18,411 they paid to [current servicer] for that year, they would have been entitled to deduct $50,046 of mortgage interest on their [year-at-issue] return. At trial, Mr. Igboke provided no explanation for why the Igbokes claimed a lower amount on their [year-at-issue] return. Moreover, the Transaction History provided by [prior servicer] refutes Mr. Igboke’s claims and shows no payments of any kind after [prior year]. Transcript, at pp. 11-12.

Confronted with these inconveniences, Henry claims former servicer told him he could carry forward the prior year’s overage. “Mr. Igboke says he relied on this advice from [prior servicer] despite his 30 years of experience as a CPA and [prior servicer] ‘s lack of authority to create tax rules.” Transcript, at p. 12.

IRS wins.

Another granite-mining Dixieland Boondockery founders in Rising Rock Partners, LLC, Robert Schill, LLC, Tax Matters Partner, T. C. Memo. 20-260-45, filed 6/2/26. It’s conjoined for trial and briefing with Edgar F. Yost, III and Deborah A. Yost; yes, that Ned Yost, the man with the two (count ’em, two) World Series rings.

But the granite-mining discounted cash flow appraisals crater, as the locals in Meriwether County, Jawjuh, don’t want granite mines in their rural hideaway. Anyway, forecasting  the results of a successful operation over 17 (count ’em, 17) years, even if the zoning objections could be met, is too speculative. The comparable sales (including Ned Yost’s own sale to the syndicators) set up a 40% gross overvaluation chop.

Judge Christian N. (“Speedy”) Weiler lists all the usual cases that have featured in the SCE saga, most of which I’ve blogged and the trade press has waded through exhaustively.

Also today we have the return of Sammy, trusty attorney, whom we saw last month in my blogpost “Five, Seven Eight, Fourteen,” 5/8/26. Now Sammy represents Mize Farm, LLC, Design, Inc., Tax Matters Partner, Docket No. 8979-23, filed 6/2/26 (Happy Palindrome Day!). Last year Judge Ronald L. (“Ingenuity”) Buch denied the Mizers their SCE write-off in an off-the-bencher, for which see my blogpost “Luke 18:14,” 12/1/25. Now Sammy wants to try Jarkesy and postponement of interest per Section 170(h).

Problem is, neither was argued until the Rule 155 beancount, which Judge Ingenuity Buch says no can do. Anyway, interest computations are not on the Rule 155 menu.