No cases out of Tax Court on May 11, but one typo in an order is worth noting. The order is Leona Allen, Docket No. 3680-12S, served 5/10/12. Chief Judge Colvin wrote: “No notice of determination concerning collection action was attached to the petitioner nor has petitioner produced one. Accordingly, the Court lacks collection jurisdiction with respect to petitioner’s taxable years 1993, 1994, and 1995.” Order, at p. 2 (Emphasis added.)
You may or may not wear your heart on your sleeve, but you’d better staple a Notice of Determination to your chest when you show up in Tax Court.
Taishoff Law 
That’s funny!
I’ve noticed several typos in cases recently, such as this one from 138 T.C. No. 18, Hershal Weber (5/7/2012): For purposes of the Commissioner’s motion, we assume correct the facts asserted by Mr. Weber and supported by his exhibits, as well as facts demonstrated by the Commissioner that Mr. Weber did not dispute.
So which is it? Assume or correct?
I’ve contacted the court in the past about typos, but never heard anything back. Does it matter if they make mistakes (besides just looking unprofessional)?
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I suppose the problem is the volume of orders and decisions with which each Judge must deal. Perhaps they haven’t time to read what the clerks turn out. The “assume correct” might barely scrape by as acceptable, but “assume to be correct those facts” would be a better locution.
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