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.

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.”

Tax Court resolves cases by means of orders, summary opinions (Rules Title XVII Small Tax Cases), memoranda (regular cases), and T. C.s (Tax Court Opinions). The old Tax Court website, now obliterated by DAWSON, used to describe the difference between memoranda and T. C.s thus: “Generally, a Tax Court Opinion is issued in a regular case when the Tax Court believes it involves a sufficiently important legal issue or principle.” “Generally, a Memorandum Opinion is issued in a regular case that does not involve a novel legal issue. A Memorandum Opinion addresses cases where the law is settled or factually driven.”

An order can, and often does, finally dispose of a case. The most common examples are dismissal for want of jurisdiction, want of prosecution, failure to state a claim upon which relief can be granted, or Rules Title XII Decision Without Trial.

Off-the-benchers can serve as decisions or orders per Section 7459(b).

Fair enough. But what’s missing from this picture?

Judgments.

Unlike State Courts and most Federal Courts, Tax Court issues no judgments. Section 7459 only permits “reports and decisions.” But I’ve never seen a Tax Court “report” that disposes of a case. Have you?

Motions for “judgment on the pleadings” (Rule 120) and for “summary judgment” (Rule 121) are FRCP transplants, apparently so named because of practitioner familiarity, but no order or opinion granting or denying either is ever labeled a “judgment.”

This is what kind of mischief I get up to on days when there’s no opinion or order worth recording.