No, not me, STJ Lewis (“The Name Correctly Spelled”) Carluzzo, in a designated hitter on a day when good blogfodder is in short supply. Not much of a big noise on Guy Fawkes’ Day, for my UK readers.

The designated hitter is Wayne D. Ramsey, Docket No. 15959-14, filed 11/5/15.

Wayne D. wants STJ Lew to take judicial notice of his two Forms 1040X for the year in dispute, and he attaches these to his motion papers.

No can do, says STJ Lew.

“Although the parties may ultimately agree upon petitioner’s… Federal income tax liability and deficiency, if any, establishing those amounts by judicial notice as requested in petitioner’s motion is not appropriate. Only facts that are not subject to reasonable dispute may be judicially noticed. See Rule 201(b), Federal Rules of Evidence; I.R.C. §7453.” Order, at p. 1.

But there is a dispute. The petition and answer show the parties dispute Wayne D.’s liability, and nothing since the time for pleadings or amendments thereto has closed shows the parties resolved the dispute.

So go fight it out, guys. Or settle.