In Uncategorized on 07/23/2014 at 17:06

No, not Rudy Kipling’s celebrated Boer War poem that made the Blighty hit parade when Sir Artie Sullivan put a tune to it. This is the story of Paul O. Reynolds, Docket No. 7405-14S, filed 7/23/14, a designated hitter that makes blogging Tax Court fun.

Paul petitions, apparently from a NOD, but he and IRS both agree there never was a NOD, it was a SNOD.

So when The Judge With a Heart, STJ Armen, tells Paul to produce said SNOD, Paul “… argues that he never received the original notice of deficiency and that the incomplete copy attached to the Supplement Objection was all he has.” Order, at p. 1.

IRS says oh yes, there was a SNOD, and Paul petitioned that SNOD a year ago.

STJ Armen pores through the files, and finds “…a timely petition was filed with the Court on July 9, 2013, in response to a notice of deficiency for tax years…. A copy of relevant pages of the deficiency notice… was attached as an exhibit to the petition. After the Court issued two separate Orders…directing petitioner to ratify the petition…, the case… was closed by Order Of Dismissal For Lack Of Jurisdiction… on the ground that the petition was not properly executed by petitioner as required by Tax Court Rules of Practice and Procedure. Petitioner did not move to vacate that Order of Dismissal, and it became final….” Order, at pp. 1-2. (footnotes omitted).

I omitted the footnotes, but read them both. Footnote 1 says the addresses on the SNOD, the petition in Case No. 1 and the petition in this case were all the same address. Footnote 2 says both orders told Paul to properly execute the petition or face dismissal; he didn’t and he did.

Sorry, Paul. No jurisdiction. No excuse for being absent-minded.




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