Credit is due constant reader Bob Kamman, Esq., for pointing out a seemingly innocuous request by Ch J Patrick J. (“Scholar Pat”) Urda in Capitol Places II Owner, LLC, Historic Preservation Fund 2014 LLC, A Partner Other Than the Tax Matters Partner, Docket No.  16536-23, filed 6/12/26.

Unhappily, the DAWSON Genius Baristas have posted this order in a format wherefrom I cannot cut-and-paste, but possibly their reason in this case is made clear in the text.

Could someone have tinkered with the language of a Supreme Court opinion? Check out a trusted version of 464 US 386, at p. 391. Then compare with Order, at p. 1.

The refrain of the Mexican folksong first quoted at the head hereof may be the answer.

Two (count ’em, two) entries for the scrapbook today, one a recurring tale and one where a word of instruction is better than a slammed door.

I’m sure all my readers join me in wishing John R. Dee, Docket No. 12649-16 W, filed 6/12/26, a speedy return to good health. John was here two (count ’em, two) years ago; see my blogpost “Watching Fewer Sunsets in Ogden,” 8/14/24. Now John is protesting an IRS status report, apparently filed while John was sick. STJ Diana L. (“Sidewalks of New York”) Leyden recharacterizes John’s filings and tells IRS to reply to John’s motion to supplement the administrative record. Taishoff says it is unbelievable that ten (count ’em, ten) years after the petition was filed, there should be any question about what comprises the administrative record. Jarndyce v. Jarndyce has nothing on these guys.

Robert Grafton, Docket No. 18878-24, filed 6/12/26, thinks he prevailed when IRS folded pre-trial, so he refuses to sign a stiped decision. He claims the stip as drafted lets IRS off the hook for Section 7430 admins and legals and wants discovery. Ch J Patrick J. (“Scholar Pat”) Urda blows that off. How he does it is what I question. 

“As stated in respondent’s response to petitioner’s Motion, respondent has conceded the determinations made in the notice of deficiency on which this case is based. It thus appears that petitioner’s discovery request would pertain only to litigation costs and to potential actions brought outside of this Court, and would not be ‘relevant to the subject matter involved in the pending case,’ i.e., to the determinations made in the notice of deficiency.” Order, at pp. 1-2. (Citing Rule 70(b)(1)).

OK, but since Robert is pro se, how about a hint that if he wants Section 7430 relief, maybe so might could be he should check out the statute and Rule 231(a)(2)(C)?

I’ve often questioned why Tax Court Rules prohibit omnibus motions and multiplex EoAs. Judge Courtney D. (“CD”) Jones provides an answer in Staven A. Stover & Cynthia Stover, Docket No. 6836-24L, filed 6/11/26. Staven & Cynthia fire off a salvo under the heading of “Answer”: a Motion to Remand, a Motion to Supplement the Admin Record, a Reply to Respondent’s Answer, and a Cover Letter to Appeals.

There’s “omnibus” and then there’s “buckshot.”

Judge CD Jones is not having any of it.

“The Court has repeatedly advised petitioners that compound filings are improper; they do not conform to the Court’s Rules (see Docs. 30, 45). Petitioners must file motions directly with the Court in the manner prescribed by the Court’s Rules, which are available on the Court’s website. If petitioners wish to re-file the documents mentioned above, then petitioners must file each document separately in accordance with the Court’s Rules. Accordingly, the Court will strike petitioners’ Answer (Doc. 46).” Order, at p. 1.

Deer-in-the-headlights pro ses should check out the “Guidance for Petitioners” link on the Tax Court website, and e-mail the DAWSON Genius Baristas support crew (although Taishoff says don’t expect much).

Finally, Staven & Cynthia might try a LITC; that’s their best bet. 

Another compound that needs breaking is the term “Power of Attorney.” Judge James S (“Big Jim”) Halpern, confronted in Edward H. Fitzelle & Jane E. Croes,  Docket No. 13476-25L, filed 6/11/26 with Form 2848, designates an individual as a Power of Attorney; Form 2848 does not. Form 2848 designates a “Representative.” Form 2848 is a Power of Attorney, hence either a piece of paper or a concatenation of electrons. Forms of power of attorney other than Form 2848 designate an “Agent” or “Attorney-in-Fact.” Sometimes the last named is abbreviated as “AiF”. But all such forms are just that: forms. Why not just call a Representative a Rep, to distinguish that person from a Partnership Representative, or P-Rep?