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That appellation has been vacant nearly seven (count ’em, seven) years since STJ Robert N. Armen retired. I must admit I haven’t been casting around for a successor to the title; I hadn’t thought to poll my readers.

So herewith an apology. Kindness overlooked is kindness diminished, and in a world conspicuously lacking that I should not participate in its further diminution.

So I nominate Judge Elizabeth A. (“Tex”) Copeland for that distinction. I proffer Retha R. McCoy, Docket No. 9279-23L, filed 2/5/26 in support.

While sustaining the Supplemental NOD (NITL for civil tax debts, not restitution and not previously levied), Judge Tex Copeland offers Retha hope that her home won’t be sold from under her.

“She has stated that she owns her home but has few other assets, and she is worried about being made homeless if the IRS takes her home. We note that there are additional steps the IRS must take in foreclosing on a person’s principal residence. To levy (take) Ms. McCoy’s principal residence, the IRS would need to get the approval in writing of a United States District Court judge or magistrate. See I.R.C. § 6334(e). To do this, the IRS would need to show that it has no other reasonable way to collect Ms. McCoy’s debt, and that it followed all the applicable laws and procedures relevant to the levy. See Treas.Reg. § 301.6334-1(d). Ms. McCoy would have a chance to try to show otherwise. See Treas. Reg. § 301.6334-1(d).

“Going forward Ms. McCoy may find it helpful to contact a low-income taxpayer clinic in New Jersey or New York for advice, such as: Rutgers Federal Tax Law Clinic, Newark, NJ, at 973-353-1685; Northeast New Jersey Legal Services LITC, Jersey City, NJ, at 201-792-6363; or Legal Services of New Jersey Tax Legal Assistance Project, Edison, NJ, at 888-576-5529.” Order, at pp. 6-7.

And this even though Reba isn’t exactly an injured innocent.

I’m not changing Judge Copeland’s cognomen here, but I want to note her sympathy. 

And Retha, call Sandy Freund, Esq., at Rutgers.

Eighty percent of Tax Court petitioners are self-represented.

When I consider the wasted time and clerical and judicial brainpower caused by good-faith Tax Court  pro ses, to say nothing of the (possibly) greater amount squandered on bad-faith gameplayers and dodgers, I shake my head. Whatever the expense of an Office for the Self-Represented, such as many courts, State and Federal, already have, I cannot understand why US Tax Court hasn’t the same.

Two (count ’em, two) cases in point.

Scott M. Balotin and Ellen M. Balotin, Docket No. 9174-25P, filed 2/4/26, is only tangentially about a passport grab, because IRS reversed the certification and told DoS, so Judge Goeke moots that out. The penalty abatement case is mooted out because a stiped decision in another case says the don’t owe any penalties for that period. Interest abatement must await trial because petitioners claim they filed Form 843, but IRS says they haven’t got it. Nevertheless, IRS agreed to the stiped decision, so let IRS show why the proffered Form 843 shouldn’t be considered as an administrative request for abatement of interest. Finally, Ellen’s innocent spousery claim. “Petitioners have not established that Ms. Balotin filed or made an administrative request for innocent spouse relief with the IRS. Also, they have not produced a Notice of Final Determination relating to Ms. Balotin’s request for innocent spouse relief. Nor have they asserted that they filed or made an administrative request or received a Notice of Final Determination. Accordingly, we do not have jurisdiction to determine whether Ms. Balotin is entitled to innocent spouse relief….” Order, at p. 2.

Couldn’t a clerk sort this out?

Next, Andre Pierre Harris, Docket No. 15845-25, filed 2/4/26, is apparently the sort of thing STJs see every day. There’s a petition with no attachments, which IRS moves to dismiss, to which there is a response that agrees, from someone claiming authority but not producing proof. I’ll let ex-Ch STJ Lewis (“My Kind of Name”) Carluzzo explain. “The Court notes that the pattern of allegations in the petition in this case, more or less, is identical to the pattern of allegations made in petitions in hundreds of other cases filed in this Court that involved taxpayer/petitioners who were apparently ill-advised. We accept, if only in the absence of anything that establishes otherwise, B’s authority to have appeared at the hearing on petitioner’s behalf but otherwise reject many of the answers that she gave in response to questions by the Court.” Order, at p. 1. (Name omitted).

“Hundreds of ill-advised taxpayer/petitioners” clogging the system to the detriment of those with meritorious claims.