In Uncategorized on 09/16/2016 at 15:09

And IRS Watch Your S’s

Ch J L. Paige (“Iron Fist”) Marvel is befuddled by the curious case of Lynette L. Lawrie, Docket No. 16198-15, filed 9/16/16.

First, Lynette sends in what appears to be a petition from a NOD after a CDP. My sharp-eyed readers doubtless noted that the letter “L” does not appear in the caption. There’s no NOD attached either, just “…a letter from Internal Revenue Service (IRS)…, which appeared to have been sent to petitioner in response to a request for 2014 wage and income forms and/or information.” Order, at p. 1.

Now IRS gets into the act.

“Subsequently…, respondent filed an answer to the petition. However, respondent failed to attach thereto any notice of deficiency or determination. Instead respondent merely denied that any notice conferring jurisdiction on the Court was issued…, without otherwise suggesting that any motion or other steps would follow to address the jurisdictional status of this case. Inexplicably, answer also closed with a prayer that ‘respondent’s determination, as set forth in the notice of deficiency, be in all respects approved’.” Order, at p. 1.

So poor Judge Iron Fist is asked to confirm a SNOD, when Lynette asked for review of a NOD, but there’s neither in the record. Because maybe there’s neither in existence.

Not to be outdone, Lynette wants to add an “S” to the caption, ignoring whether an “L” should be added as well.

OK, but Ch J Iron Fist has no idea whether she’s got a SNOD or a NOD, or maybe nothing, to deal with, and, if she has either, whether $50K is involved.

Would IRS please tell her.

And just in case Ch J Iron Fist, an honors graduate of the University of Maryland Law School, partner or shareholder in numerous white-shoe law firms, and member of numerous blue-ribbon panels, hasn’t enough clerical work to do, here’s Jallad Corporation, Docket No. 14097-16S, filed 9/16/16.

The Jallads amended their petition to add the missing “S”, as they want small-claimer treatment. IRS answered, but were a wee bit casual in their response.

Ch J Iron Fist: “…respondent filed an Answer To Amended Petition, in which the caption is incorrect in that the ‘S’ is not included in the docket number for this case. Accordingly, we will strike that document from the record.” Order, at p. 1.

Ch J Iron Fist orders IRS to file an amended answer to the amended petition with the right caption, including without limitation the correct docket number with the capital “S.”

That’ll show ‘em, Judge.



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