No, I’m not going to insult my ultrasophisticated readers by telling them about IRS’ Refund Tracker. No one who reads this my blog needs such babyfood. Rather, this is the story of Renee Elaine White, Docket No. 878-26S, filed 4/21/26, who wants Tax Court to give her “reimbursement for payments made with respect to the 2014, 2015, 2016, and 2017 tax years, for which petitioner was granted innocent spouse relief pursuant to Internal Revenue Code (I.R.C.) section 6015(c).” Order, at p. 1.

Renee stiped out her innocent spousery last October, no runs, no hits, no errors (no tax due, no refund due, no penalties due). But Renee claims runners left on base for the said four (count ’em, four) years of spouse’s tax obligations. IRS ripostes with “no SND, no NOD, no jurisdiction.”

Ch J Patrick J. (“Scholar Pat”) Urda calls Renee out at Tax Court.

“…the relief requested by petitioner—refunds for various tax years —is not within the Court’s authority to grant in this case. In a case based on a notice of deficiency, in which the Court must determine the correct amount of tax, this Court may make a determination concerning whether there has been an overpayment of tax. See I.R.C. § 6512(b). Otherwise, this Court does not have jurisdiction to make determinations concerning overpayments or refunds. Taxpayers generally have two years to file a lawsuit following the disallowance of a claim for refund. See I.R.C. §6532(a)(1). The Tax Court, however, is not the proper court in which to file such an action. A taxpayer may seek a judicial remedy for wrongful denial of refund claims—i.e., a refund suit in compliance with I.R.C. sections 6532(a)(1) and 7422(a)—either in the United States Court of Federal Claims, pursuant to 28 U.S.C. section 1491(a)(1), or in Federal district court pursuant to 28 U.S.C. section 1346(a)(1). Those statutes do not confer refund jurisdiction on the Tax Court. Accordingly, this Court cannot and does not decide whether petitioner is entitled to recover a refund….” Order, at p.2.

Edited to add, 4/21/26: Even if Tax Court had jurisdiction, see Order at p. 2. Renee submitted Form 843 refund claim two (count ’em two) months ago. Section 6532(a)(1) imposes a six-month cooling off period before a refund suit can be commenced, unless IRS sooner denies (which Renee doesn’t allege).

I had hoped to pass on to you some enlightenment anent the Families First Coronavirus Response Act (FFCRA), Pub. L. No. 116-127, §§ 7002, 7004, 134 Stat. 178, 212, 217 (2020) (as amended by the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. N, § 286, 134 Stat. 1182, 1989 (2020)), and those enacted by the American Rescue Plan Act of 2021 (ARPA), Pub. L. No. 117-2, §§ 9642 and 9643, 135 Stat. 4, 171, 174 (2021). 

Alas, Judge Kashi (“My or the High”) Way gives us nothing but a defective-documentation case that, in his words, “… go beyond poor recordkeeping and suggest pure fabrication,” Marie M. Kanda, T. C. Sum. Op. 2026-3, filed 4/20/26, at p. 9. (Footnote omitted).

I leave it to you to read Judge Way’s unbaling of Marie’s various reporting positions. I really stopped following them, although Marie’s list of ailments at p. 2 did evoke enough sympathy for me to understand why IRS folded the Section 6676 excess deductions and credits chop.

Most motions to proceed remotely fail for mootness, either jurisdictional footfaults or stipouts. Fullview, Inc., Docket No. 16901-23, filed 4/20/26, applies Rule 140(b) to a motion made three (count ’em, three) weeks before trial, to which IRS successfully objects.

Fullview claims its request for trial in San Diego was a mistake, as its representative lives near San Francisco.

“Respondent objects to petitioner’s Motion stating that (a) petitioner has had multiple opportunities over the past three years since petitioner filed the petition to identify the mistake and has failed to do so, (b) petitioner’s internet has frozen on numerous occasions when virtually conferencing with respondent, and (c) because the primary issues for this case are document intensive, the trial is not conducive to a virtual proceeding.” Order, at p. 1.

Judge Benjamin A. (“Trey”) Guider, III, tells Fullview to show up in San Diego.

“Rule 140(b) of the Tax Court Rules of Practice and Procedure allows a party to move to change the place of trial, but states that if the ‘motion [is] made after the notice setting the case for trial is served[, it] may be deemed dilatory and may be denied unless the ground therefor arose during that period or there was good reason for not making the motion sooner.’ Petitioner’s reasons for requesting a remote proceeding do not meet this standard and seemingly did not arise between our Order setting this case for trial and petitioner’s Motion to Proceed Remotely. And respondent has raised convincing objections.” Order, at p. 1.