Attorney-at-Law

“NOT EVEN THE CHAIR”

In Uncategorized on 10/21/2026 at 18:04

No, not an off-topic essay about existential angst (although who knows how low this my blog may sink before I’m done with it?), this is about V, an attorney subject to State Court discipline. Name omitted, of course; said attorney has already suffered enough.

Too often, Tax Court admittees who get wigged or gigged by other tribunals never tell the Glasshouse Gang. But V did tell Tax Court, asking to be relieved in a pending case because of the State Court suspension order.

Ch J Patrick J. (“Scholar Pat”) Urda does credit V that far, but that wasn’t far enough for Rule 202(b).

“A member of the Bar of this Court is required to report to the Chair of the Court’s Committee on Admissions, Ethics, and Discipline, in writing, of suspension by another Court of whose Bar such attorney is a member no later than 30 days after entry of the order of discipline. Rule 202(b), Tax Court Rules of Practice and Procedure. Although [V] did not report her suspension to the Chair, she did report the suspension to the Court, in writing, within, 30 days of her suspension from the practice of law….” Order, at p. 1.

OK, the Rule says what it says. But who is the Chair? You won’t find him or her on the Tax Court website. The website Court directory lists admissions with a telephone number, but seems to restrict its function to “(A)dmissions procedures for practice before the Tax Court and practitioner access for DAWSON.” General questions go to Public Affairs.

So to whom and where does the disciplined practitioner, smarting from the wounds righteously administered, direct the notice to the Chair in writing? Or did Neil Diamond get it right fifty-five (count ’em, fifty-five) years ago?

WIDENING DAWSON’S CREEK

In Uncategorized on 10/21/2026 at 17:22

Ch J Patrick J. (“Scholar Pat”) Urda has bestirred the Genius Baristas and the 18-Fs to new efforts to improve the reach and scope of DAWSON.

Commencing New Year’s Day next, all motions newly filed on or after 1/1/27, plus any briefs or memoranda in support of such motions, that are electronically filed by practitioners who are admitted to practice before the Court will be made available to the public remotely through DAWSON, the Court’s electronic filing and case management system. Oppositions to such motions that are electronically filed by practitioners who are admitted to practice before the Court will likewise be made available to the public remotely through DAWSON. Motions filed before said date will continue to be available through a records request to the copycats or at the public terminal available at the Glasshouse. Although this new feature may be implemented after January 1, 2027, it will be effective with respect to motions filed on or after that date.

Note this applies only to practitioner motions, briefs or memos; pro se stuff will be limited because of Section 6103 gaffes and redaction failures.

Practitioners are admonished to follow Rule 27 and scrub their public filings.

A SUCCESSFUL SUPPLEMENT

In Uncategorized on 10/21/2026 at 17:05

Don’t get me wrong here; I am definitely not saying that Veronica Kyler, Docket No. 782-26L, filed 10/21/26, will win either her innocent spousery claim or her fight about the $500-a-throw chops for want of diligence in ascertaining eligibility for HOH filing status or other tax benefits per Section 6695(g) because of her successful motion to supplement the administrative record.. Kyler is clearly a preparer for whom this is not her first rodeo, which is why IRS put three (count ’em, three) attorneys on this case.

Kyler admits she’s late with her Rule 93 motion because she blew the arithmetic, but Judge Morrison allows the late filing, as trial isn’t for another forty days and there are “other circumstances” that outweigh IRS’ objections. Order, at p. 3.

“The only documents attached to the Motion to Complete or Supplement the Administrative Record are (1) an Examining Officer’s Activity Record…; (2) a letter with an illegible date from Revenue Agent D to Kyler requesting a response by February 28, 2020; and (3) a letter from Kyler stating that she did not agree with ‘the finding of Civil Penalties by Revenue Agent D.’ The Motion further requests that the Court order respondent to identify or produce additional documents.” Order, at p. 3. (Name omitted).

IRS says Kyler is trying to relitigate underlying liability, for which she already had a chance at a prior hearing at Appeals. Judge Morrison says the documents are clearly relevant, IRS doesn’t claim they’re phony, and Appeals did consider them.

“Because the Court has not yet resolved whether Kyler had a prior opportunity to contest her underlying liability, it would be premature to exclude evidence from the trial record on the grounds that she is precluded from disputing her underlying liability.” Order, at p. 3.

But her request for IRS to identity or produce additional documents fails because outside the scope of Rule 93.

Note that innocent spousery is involved here (see Order, at p. 2), so there may be a lot more to this case than the narrow issue involved here.

Kyler gets a Taishoff “Good Job.”