No, not a law firm (although it could be an appropriate moniker for several I know of), but rather the sad tale of Johnny Steven Vallejo, Petitioner, and Elfida O. Vallejo, Intervenor, 11397-11S, filed 4/9/13, a designated hitter from Judge Daniel A. (“Yuda”) Guy, Jr.

Johnny Steven stips to entry of an order that he’s not an innocent spouse. What Elfida does is not stated. After the 90-day Section 7481(b) period has run and the stipulated order is final, and the Rule 162 30-day period for moving to revise or set aside has run, Johnny Steven moves to set aside.

Johnny Steven claims he has Post Traumatic Stress Disorder and was confused about the effect of the stip he signed.

That’s a thwacking great xin loi, good buddy, says Judge Yuda.

“The Tax Court normally lacks jurisdiction to vacate a decision once it becomes final. The Court of Appeals for the Ninth Circuit recognizes a narrow exception to the general rule, holding that the Tax Court may vacate an otherwise final decision if it was obtained through fraud on the Court.” Order, at pp. 1-2. (Citations omitted). The Ninth Circuit gets involved as this is a California case, appealable to Ninth Circuit.

Johnny Steven doesn’t claim he was defrauded, or that the Court was defrauded. He was confused.

No good. I have no jurisdiction to set the stipulated order aside, says Judge Yuda.

Nothing like litigating with a confused, traumatized and stressed self-represented, huh, IRS?