It’s a dull day in the Glasshouse (for you who haven’t crossed the sacred portals, the Glasshouse is 400 Second Street, NW, in Our Nation’s Capital); five (count ‘em, five) T. C. Memos today, but only one of interest, and him I’ll blog separately.

But Ch J Michael B. (“Iron Mike”) Thornton is again emulating Goeff Chaucer’s Clerke of Oxenford in M. W. Miozzi Homes, Inc., Docket No. 1136-15, filed 3/16/15.

Take it away, Geoffrey:

“Not one word spake he more than was need;
And that was said in form and reverence,
And short and quick, and full of high sentence.
Sounding in moral virtue was his speech,
And gladly would he learn, and gladly teach.”

And IRS’s counsel is on the receiving end of Ch. J Iron Mike’s gladly teaching.

IRS says the petition was signed by Michael Miozzi, who identifies himself as president of M. W. Homes, Inc. M. W. Miozzi Homes, Inc., was inc’ed in Ohio. Ohio law says a corporation must appear by a licensed attorney-at-law. But Mike isn’t an attorney. And Tax Court Rule 60(c) says the authority of a fiduciary or other litigant other than the party must be determined by State law.

So IRS wants the petition tossed because not properly signed.

Ch J Iron Mike to IRS: take up your little wordprocessor and answer the following midterm examination.

“In pertinent part, Tax Court Rule 24(b) provides that a corporation may be represented by an authorized officer of the corporation. See Asbury v. Commissioner, T.C. Memo. 2007-53, at *6 (noting that Rule 24(b) allows an authorized officer of a corporation to represent the corporation in this Court ‘without counsel’).” Order, at p. 1.

Here’s the exam question: “…on or before April 6, 2015, respondent shall… set forth and discuss fully his position as to whether Tax Court Rule 24(b) allows Michael Miozzi to represent M.W. Miozzi Homes, Inc., in this case.” Order, at pp. 1-2.