Attorney-at-Law

“I PRAY YOU, GIVE ME LEAVE TO GO FROM HENCE”

In Uncategorized on 11/13/2015 at 16:47

Both IRS and Bohdan Senyszyn so request STJ Panuthos although not exactly in haec verba from Act IV, Scene 1 of The Merchant of Venice. But unlike the Duke in Shakespeare’s controversial masterpiece, STJ Panuthos doesn’t.

The story is in Bohdan Senyszyn, Docket No. 14372-11, filed 11/13/15.

You remember Bo. No? Then check out my blogpost “The All-Star Break,” 5/20/15, wherein I recounted Bo’s unsuccessful whistleblowing.

IRS bounced Bo’s initial effort with a “no dough, no go” letter, from which he petitioned. Then IRS sent him another letter, saying they were reopening Bo’s claim. This they followed with another bounce, so Bo petitioned again.

He and IRS agreed that the outcome from Petition No. 1 would govern Petition No. 2.

So now it’s all final, and Bo is getting nada.

So let’s end the misery, right?

Not so fast, says CSTJ Panuthos.

“The Court also notes that despite the parties’ agreement that this docket may be dismissed for lack of jurisdiction, the parties may not expand or contract the Court’s jurisdiction. Ringo v. Commissioner, 143 T.C. 297, 299 (2014). We are satisfied that we have jurisdiction in this docket since there was a determination and timely petition filed. Id. Accordingly, the Court will order the parties to show cause as to why this case should not be disposed of on the same basis and consistent with the Order and Decision entered in the case at Docket No. 14703-13W.” Order, at p. 3.

Typo, Judge? Don’t you mean 14706-13W? Docket No. 14703-13 isn’t a Section 7623 whistleblower.

The Ringo case involved a similar request, when both IRS and Ringo agreed that they would work out their salvation out of Court, but Judge Colvin stood on the dignity of the Court. See my blogpost “Let’s You and Him Fight,” 10/9/14.

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