I often wonder if this my blog (and I, its “onlie begetter”) takes itself (and I myself) too seriously. I’ve been accused of making light of Tax Court litigants’ dilemmas, even if their wounds are self-inflicted and their errors unforced. I often make unasked-for comments on Tax Court Rules and procedures, with a certain Olympian (if not Sinaiatical) detachment.

So today, something on the lighter side.

Saul Steinberg’s immortal New Yorker magazine cover made fun of the insularity of us denizens of this Minor Outlying Island off the Coast of North America. I referred to it more than once under the rubric “Everything West of the Hudson is Kansas.”

Judge Rose E. (“Cracklin'”) Jenkins is by no means insular. Judge Jenkins merely wants to get the mail to the proper destination in Hassine Sidane, 11877-25, filed 10/16/26.

With 30 (count ’em, 30) days to go before trial and an IRS motion for judgment on the pleadings awaiting reply from Hassine, “(P)etitioner has not filed a response to the motion and has not responded to attempted e-mail communication from the chambers administrator of the undersigned.” Order, at p. 1.

Default looms. But Judge Jenkins to the rescue.

“However, review of the record in this case indicates that petitioner’s address of record in this case is stated as in Dran Oran, rather than Oran Oran, as reflected in the address to which the Notice of Deficiency was mailed. Accordingly, the Court will update the address of record to be consistent with the latter, re-serve the relevant documents in this case, extend the time for petitioner to file a response, and set this case for hearing.” Order, at p. 1.

Apparently to IRS, everything east of Holtsville…but you know the rest.

There’s a need to provide a safe road to public filing of redacted Excel spreadsheets, heavy-laden with “metadata, formulas, hidden worksheets, hidden rows or columns, comments, notes, named ranges, pivot tables, cached values, document properties, external links, macros, filters, and other embedded workbook features.” So opines Judge Kashi (“My or the High”) Way at p. 4 of Marc Worrall & Sue J. Worrall, et al., Docket No. 14793-22, filed 10/15/26.

This is Discovery Kerfuffle No. 4 that I’ve blogged in this ongoing drama.

A fight over the filing of redacted trial exhibits arises from IRS’ attempt to do so, claiming it has obliterated any PII or other matter shielded by Judge Way’s previous protective order. Marc’s & Sue’s nine (count ’em, nine) trusty attorneys  object, citing the Excel spreadsheets’ backchannel porosities, trapdoors, and hidden interstices as hereinabove set forth.

So Judge Way sets up a phoneathon. 

“We agree with petitioners that respondent’s broad assurances that the exhibits have been properly redacted are insufficient to establish that confidential information does not remain accessible through metadata, formulas, or other embedded features. We are especially cautious where, as here, many of the exhibits are Excel workbooks with complex file structures spanning thousands of pages. We would have expected, at minimum, exhibit-by-exhibit descriptions of what information was removed and a technical certification describing the steps taken to remove it. Even so, risks remain.” Order, at p.3.

So tech-savvy Judge Way finds an Adobe-lined path that satisfies everyone, IRS, Marc & Sue, and the third-parties subpoenaed into this slugfest.

“The Court proposed that respondent instead convert the relevant portions of the Excel files to PDF format and perform his proposed redactions directly on the PDFs to avoid the risk that confidential information remains embedded in the file structure. Both parties agreed that this was a workable solution.” Order, at p. 3.

I know the native-format crowd will yell that villainous PDF digg’d out of exhibits all that backchannel stuff they so need to eyeball. But parties and third-parties can still scope the stuff in secret, and the data they see in secret will reward them.

No, not another microcaptivity dodge; this is STJ Jennifer E. (“Publius”) Siegel adding a gloss to the NY-NJ rivalry. Writing from a trial session on this Minor Outlying Island off the Coast of N. America, STJ Publius Siegel assures Bruce Ammerman, Docket No. 11069-25, filed 10/14/26, as to the status of his home State.

“There is no dispute that the Notice was addressed to and received by Mr. Ammerman at an address in New Jersey. There is no dispute that the Petition was filed with the Court more than 90 days after the issuance of the Notice. And Mr. Ammerman does not argue that equitable tolling should apply to extend the period for filing. Rather, he contends that he was ‘outside the United States’ as he claims to understand that term and thus should be entitled to the 150-day filing period. Although polite, Mr. Ammerman is very clearly incorrect: New Jersey is part of the United States. The 90-day period applies.” Order, at p. 2.

“New Jersey is part of the United States.” Are you sure, Judge?