To begin with, I do not know the facts and circumstances that led to the trusty attorney for Linda S. Bienstock, Docket No. 11167-26S, filed 11/6/26, being admonished by Ch J Patrick J. (“Scholar Pat”) Urda that said trusty attorney “will not be associated with this case until an entry of appearance is filed in accordance with Tax Court Rules of Practice and Procedure.” Order, at p. 1.

A brief DAWSON search reveals said trusty attorney has been admitted to the Tax Court Bar for fifty (count ’em, fifty) years. A search of Our Fair State’s Office of Court Administration website shows said trusty attorney to be a member of a well-known firm located on a Minor Outlying Island off the Coast of North America adjacent to the Minor Outlying Island whereon I am writing these lines.

I cannot think the nonfiling of the Form 7 is thus a rookie error. More likely it is a case of “beat the clock,” the last-minute efiling as the Section 6213(a) 90-day window expired. As the petition was filed 11/2/26, I would expect that said trusty attorney, having beaten the clock, thought he could take a breath and prepare and file the proper documentation later this week, having put out whatever other fires he had burning on Monday.

Tax Court procedure relies so heavily upon public orders that a phonecall or an email from one of Chief Clerk Jeane’s minions to said trusty attorney, along the lines of “hey, guy, file an EoA, OK?” is out of the question.

Taishoff asks whether scarce judicial resources cannot better be employed.

IRS claimed Adam Hockley, Docket No. 14940-25, filed 11/6/26, dropped off the grid. For that reason, IRS’ counsel sought to toss Adam’s petition for want of prosecution. So at calendar call in The Best Location in the Nation, Judge Courtney D. (“CD”) Jones promised to toss Adam’s petition “soon.” Order, at p. 1.

But Judge CD Jones is nothing if not meticulous.

“After further review of the motion and the record, the Court will direct respondent to make additional attempts to contact petitioner.” Order, at p. 1.

Where most jurists would clear Adam’s petition from the goalmouth to the far boards, Judge CD Jones tells IRS’ counsel to try once more to raise Adam on the blower.

“Respondent’s motion represents that petitioner did not provide a telephone number or email address where he can be reached (Doc. 10, Par. 7). But the Court observed that the UPS label that was used to mail the Petition lists a telephone number under petitioner’s name (Doc. 1, PDF Pg. 4). The telephone number can be seen in the upper left hand corner of the UPS label (Doc. 1, PDF Pg. 4).” Idem, as my expensive colleagues would say.

So IRS has two (count ’em, two) weeks to try to reach Adam on the UPS label phone number and report the results to Judge CD Jones.

My kind of judge.

Maurice Butler, T. C. Memo. 2026-116, filed 11/5/26, has a basic problem that is endemic in the Section 152 cases. I’ve chronicled again and again the Section 152(c)(1)(B) “same principal place of abode as the taxpayer for more than one-half of such taxable year” stumbling block.

Ordinarily, Maurice’s inability to clear this bar would be understandable. Shared parenting agreements rarely require documentation. But in this case, there was a court order and testimony about a logbook kept. Maurice testified on the trial about dates but produced neither.

I won’t quote footnotes 3 and 4 at p. 5 of Judge Alina I. (“AIM”) Marshall’s opinion. Maurice was represented by counsel; you may judge for yourselves the quality of that representation.