No, not applause, and certainly not for apprentice rounder Janice Marie Cross, whose recent doings featured in my blogpost “Forthright, Credible, and Largely Undisputed”, 7/24/14, although, according to that Obliging Jurist Judge David Gustafson, Janice Marie is none of the above.

Still, even an apprentice rounder and frivolity merchant is entitled to due process. So IRS must get its “Disclosure Office [to] certify the SFRs via a Form 2866, ‘Certificate of Official Record’….”. See Janice Marie Cross, Docket No. 1439-13, filed 8/1/14, at p. 1.

When Janice Marie first asked that the SFRs be certified (of course she didn’t file returns), IRS said they could do it, but why bother? They’d given her uncertified ones already, and whatever they gave Janice Marie now, she’d just dispute them anyway.

Judge Gustafson hews to the law. “Unless the parties stipulate the authenticity of the SFRs, it would seem that respondent must at trial authenticate the SFRs by means of a certificate of official record. Since the offering of such certificates seems highly likely (if not inevitable), we see no reason not to require respondent to produce them now.” Order, at p. 2.

So give it up, IRS. And Janice Marie, be careful what you ask for–you might just get it.