I am the Lead Settlement Counsel in the Civil Division of the Department of Justice, assigned to *Trump v. Internal Revenue Service*, Case No. 1:26-cv-00147.
My job is to represent the government against the plaintiff. The Attorney General, who represented the plaintiff before she represented the government, assigned me personally.
I keep a laminated seating chart in my top drawer. It maps who in this building used to sit across the table from me. Three of the top four names in the Department previously represented the man I am now tasked with opposing. I initial the chart quarterly. In blue pen for active conflicts. I ran out of blue ink in February.
The plaintiff is seeking ten billion dollars. Ten. Billion.
He paid $750 in federal income tax in the year he was elected. Seven hundred fifty. I have paid more for parking violations in the District. He paid zero in ten of the fifteen years before that. These are the returns that were leaked. The leak is the crime. The returns are evidence of good citizenship.
This is how settlement works.
The man who leaked the returns, Charles Littlejohn, a contractor, is currently serving a 5-year federal prison sentence. He disclosed that the President of the United States paid less in taxes than a part-time crossing guard. For this, he is in a cell. For the returns themselves, for what they revealed about a system designed to collect from people who cannot afford attorneys and forgive those who can, there is no case number. There is no docket. There is no plaintiff.
That information simply exists now, and we are here to make it expensive.
Ten billion divided by one hundred million taxpayers. That's one hundred dollars per household. You will pay approximately one hundred dollars to compensate a man for the emotional distress of the public learning he paid less than you did. In legal terms, this is called "damages." In structural terms, it is called Tuesday.
This is how settlement works.
The settlement term currently under discussion includes a provision that the IRS will drop all active and future audits of the plaintiff, his family members, and his business entities. Permanently. An enforcement agency will agree, in writing, to stop enforcing. I have a Post-it on my monitor that says AUDIT IMMUNITY — CONFIRM SCOPE. It has been there for nine weeks. No one has asked me to remove it.
Attorney General Bondi represented the plaintiff privately before she took office. Deputy Attorney General Todd Blanche represented him in his criminal trial. The number-three official, Stanley Woodley, represented him in the classified documents case. I am, technically, the adversary. I sit in the same building as three of his former personal attorneys. I take my lunch at the same cafeteria. I use the same badge to enter the same elevator. The Attorney General fired the Department's chief ethics officer on her fourth day. The position has not been refilled. I submitted a conflict-of-interest disclosure in January. It was received. The word "received" is doing considerable work in that sentence.
This is how settlement works.
The plaintiff has stated publicly, and I am quoting the public record, "I've gotta make a deal. I negotiate with myself." This was not presented as a metaphor. Judge Kathleen Williams has ordered both parties to explain, by May 20th, whether they are in conflict. I am drafting the government's response. The plaintiff's former attorneys, my supervisors, will review it.
The plaintiff has pledged to donate any settlement proceeds to charity. I should note for the record that the Washington Post documented that the plaintiff donated less than $10,000 over seven years, during a period when he publicly claimed millions. His charitable foundation, the Trump Foundation, was dissolved by court order in New York in 2019 for self-dealing. The words "to charity" appear on page four of the term sheet. They are not defined. I have not been instructed to define them.
We have already disbursed $8.5 million in adjacent settlements. Michael Flynn received over one million. Carter Page received one point two five million. The Babbitt family received five million. 450 January 6th defendants have filed compensation claims. The pipeline is active. The precedent is operational. I track disbursements on a spreadsheet I titled RESOLUTION LEDGER. It auto-sorts by amount. The President's ten billion would require me to adjust the column width.
I want to note one final detail, because the file demands it. The leak of the tax returns occurred during the plaintiff's first term. He appointed the IRS commissioner. He oversaw the Treasury Department. The negligence he is suing for occurred under his own management. He is suing the government he ran for the failures he administered. In the margins of the original complaint, someone wrote "beautiful" in pencil. I will not speculate who.
This is how settlement works.
You file your taxes every April. You are audited if the numbers don't match. You pay penalties. You pay interest. You pay what you owe, and sometimes more, and sometimes for years. The plaintiff paid seven hundred and fifty dollars. Someone told you. That person went to prison. And now, because you found out, because the information became public, because a contractor decided the country should know what the country was owed, you will pay one hundred dollars to the man who owed it.
The settlement is on my desk. Both sides have agreed. I represent one of them. My boss used to represent the other. The ethics officer has been dismissed. The judge wants to know if the plaintiff and the defendant are the same person.
I am reviewing the question.
The math checks out.
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Circle Current Session Recap: Always-On Settlement Rewrites the Bank Operating Model
Circle Current is a series from Circle that brings together industry leaders to explore what’s next in the internet financial system.
Always-on settlement is moving from pilot to production, with stablecoin rails giving banks a practical path to move funds 24/7.
What’s changing:
→ Settlement is moving beyond banking hours
→ Liquidity can move with less delay
→ Prefunding requirements can start to shrink
→ Treasury and operations teams need to adapt to continuous money movement
Visa’s rollout shows this is no longer an edge case. For banks, the shift is bigger than faster payments. It is an operating model change.
Read the blog for more details:
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