Peter L. Clinco v. Commissioner
US Tax Court · Feb 9, 2026
- Jurisdiction
- federal
- Court
- US Tax Court
- Record ID
- peter-l-clinco-v-commissioner-2026-02-09
- Observed outcome
- The Court admonished counsel for the use of fabricated citations but did not impose formal sanctions.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The U.S. Tax Court admonished counsel for submitting a brief containing multiple fabricated and misrepresented case citations, which the Court attributed to the likely use of generative AI. Although the Court characterized the conduct as unacceptable and a violation of Rule 11(b), it did not impose a formal monetary or professional sanction, opting instead to issue a stern warning.
Fabricated: Case Law | Counsel cited "Cacchillo v. Commissioner, 130 T.C. 132 (2008)" in support of a signature requirement; the Court found no such case at that citation and that the citation appears fabricated. || Misrepresented: Case Law | Counsel cited "Miller v. Commissioner, 57 T.C. 440 (1971)" to support a proposition about notices of deficiency; the Court observed the actual Miller decision cited by counsel is a T.C. Memo. (1984-448) and the reporter page at 57 T.C. 440 is a different case, so the citation was incorrect/misrepresented and did not support counsel's point. || Fabricated: Case Law | Counsel cited "Tefel v. Commissioner, 118 T.C. 324 (2002)" for a signature-formalities proposition; the Court found no case named Tefel at that citation (page 324 of 118 T.C. is Hillman v. Commissioner) and treated the citation as fabricated.
Tax Court reads every citation; fabricated Tax Court cites are instantly caught and attributed to AI.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Tax
- Trial
- Warning
- AI attribution
- Implied
- Recorded tool
- Large language model AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum Findings of Fact and Opinion issued by the U.S. Tax Court following a petition challenging a notice of deficiency.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The Court attributed the citations to a large language model.
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.