Bush v. United States

With respect, I concur only in the result.

On its face, this case is abstract and unapproachable; few people have ever looked at subchapter K of the tax code, let alone familiarized themselves with terms like “notice of deficiency,” “computational adjustment,” or the difference between “partnership items” and “nonpartnership-items.” I write separately to emphasize the importance of the issues at play and ramifications of the majority opinion. Ultimately, the majority and I reach the same result. However, I do so by simply applying the statute; in my view, the statute is clear, in need of no…