Ch J Patrick J. (“Scholar Pat”) Urda, whom I must think laments the Congressionally-forged jurisdictional fetters in which he is confined like a latter-day Prometheus, finally expresses same in the measured language which befits the judicial character.
Susan Marie Hansen, Docket No. 910-26, filed 5/15/26, is five-plus years late with her petition from a 2000 SND covering tax years more than thirty (count ’em, thirty) years ago.
When IRS moves to toss for want of jurisdiction, Ch J Scholar Pat reels off the laundry list of jurisdiction-conferring notices and scenarios, none of which Susan Marie Hansen has proffered.
Susan Marie Hansen’s plea is one too often heard from self-representeds.
“Petitioner was served with a copy of respondent’s motion to dismiss and… filed a response in apparent objection. Therein, petitioner did not directly counter the jurisdictional allegations set forth in respondent’s motion and did not establish that petitioner had filed with the Tax Court during the time frame relevant to any statutory notice. Rather, the submission, to the extent even minimally intelligible, seemed to reference hardships being suffered by petitioner and family members and to be a plea for some type of aid. It did not, however, appear to acknowledge the specific jurisdictional parameters in question, nor did it allude to or attach any notices from the IRS that could bear upon the jurisdictional query before the Court.” Order, at pp. 3-4.
Susan Marie Hansen is clearly frustrated, but the Tax Court train left that station years ago.
“Absent a specific statutory grant to the Court to address a particular notice or scenario, the Court has no general jurisdiction to consider and redress complaints simply because they may pertain to taxes.” Order, at p. 4.
See the headline first written at the head hereof (and hi, Judge Holmes).