Judge Kerrigan exhibits great patience, but next friend Alexander Salvagno hasn’t done much for incompetent Raul in Raul Salvagno, Incompetent, Alexander Salvagno, Next Friend, Docket No. 16800-07, filed 2/26/13, a designated hitter on a slow day in Tax Court.

Judge Kerrigan: “…we granted Alexander Salvagno’s motion to be recognized as next friend of petitioner. His motion stated ‘there is no other person better suited to serve as next friend, for the purpose of conducting the presentation of the Tax Court trial’ and assured the Court that he was ‘familiar with the facts of [his father’s] case and principles of law” from having ‘worked in a law library for nearly five years’. Despite his assurances, petitioner’s next friend has repeatedly been non-responsive to the Court’s Orders, and non-compliant with the Tax Court Rules of Practice and Procedure….” Order, p. 1.

On the day of trial, Alex asks for appointment of counsel (Tax Court doesn’t do that, and Alex was told so) and for a continuance. We all know you ask for a continuance thirty days in advance of trial, unless you have a total catastrophe. Alex didn’t.

IRS moved to dismiss for want of prosecution on two separate occasions, but patient Judge Kerrigan gave Alex more time each time.

Now she tells him the record is closed, as she has enough to decide; let Alex brief whatever points of law he has (time to hit the libe again, Alex) before April 1, 2013 (an appropriate date), or have his case tossed.

With friends like him….