The words of the late great Dr. Eric Berne echo through the ongoing saga of Mica Ringo, Docket No. 29562-12W. Mica’s and IRS’s dilemma continues to befuddle the parties, Tax Court and, last and certainly least, your most humble and obed’t servant. See my blogpost “Oh, Those Letters!”, 10/6/14.
IRS did make a determination on Mica’s Form 211, and Mica timely petitioned, but then IRS said “whoops, got it wrong, ignore previous transmission”, and moved to dismiss for want of jurisdiction. Judge Colvin said “tough table tennis, troops, it’s a determination and a timely petition and we got jurisdiction.”
Ms. Jennifer Cordaro over at CCH got some copy out of me on the subject, but I carefully refrained from giving legal advice either to Mica or IRS about what to do when they were in the ring but didn’t want to fight…yet.
And I’ll still refrain, but they have to do something, because Judge Colvin wants to push them to trial or settlement…even when they haven’t decided that they have a case or controversy, or anything to settle.
Here’s Judge Colvin: “ORDERED that the parties shall, by November 30, 2014, file a status report on this case, including actions needed to prepare this case for trial or to consider the possibility of settlement.” Mica Ringo, Docket No. 29562-12W, filed 10/9/14.
I’ll still refrain from giving legal advice to either party, but I suggest a conference call with Judge Colvin might be a good idea.
You must be logged in to post a comment.