No, not the Impalas’ 1959 hit “Sorry (I Ran All the Way Home)”, but rather Gregory Scott Savoy’s reprise of his beef with IRS.

You remember Greg claimed he hadn’t gotten a fair shake at Appeals because he is disabled, so back to Appeals he went last summer. For particulars, see my blogpost “Disabled But Rehabilitated”, 7/16/13.

Now Appeals issued a NOD that “determines that his tax accounts are currently uncollectible (not only for the 2007 year at issue here but for all years) and leaves him free to file amended returns with no defined schedule. The Court therefore directed the parties, by order dated August 15, 2013, to ‘either submit a stipulated decision document, or file a status report proposing a schedule for further proceedings, or file an appropriate motion.’” Gregory Scott Savoy, Docket No. 12316-12L, filed 9/20/13, Order, at p. 1.

Looks like Greg is a winner, right? But Greg isn’t finished; like certain other characters who show up in my blogposts, Greg is a Tax Court hobbyist. Some mothers have them, and that Obliging Jurist, Judge David Gustafson, seems to get more than his share of them.

Judge Gustafson: “…Mr. Savoy filed a 17-page status report, complaining that ‘[t]he only thing that was missing from the Respondent’s version of a stipulated decision document was an apology’ as to ‘the appropriateness of the collection actions’. The undersigned judge is unaware of any authority or rationale that would give the Court jurisdiction under section 6330(d)(1) to require an apology from the IRS, as opposed to sustaining or overruling a collection determination.” Order, at p. 1.

I don’t know of any basis for that order either, Judge.

IRS, unemotional as always, files a motion for summary judgment, affirming Appeals’ NOD letting Greg off the hook.

Judge Gustafson, rather like an indulgent but slightly out-of-patience parent, tells Greg to “…file a response to respondent’s motion for summary judgment. Mr. Savoy need not duplicate in that response the narrative in his recent status report but may instead incorporate by reference any portions of the report that he intends as responsive to the IRS’s motion.” (Emphasis by the Court). Order, at p. 2.

Judge Gustafson, be prepared for another 17 pages. I’ll bet Greg isn’t the kind that takes the hint.