In Uncategorized on 10/21/2016 at 15:04

Whatever disagreements I may have with Ch J L. Paige (“Iron Fist”) Marvel, I want to be the first to praise her for bringing to the attention of the self-represented the counter to the IRS one-two punch I’ve often faulted heretofore.

For details, see, e.g., my blogpost “Fake Out – Part Deux,” 6/23/15.

IRS seems to like this move, bombarding the pro se taxpayer with stuff that looks like a SNOD, but isn’t, even though there’s no mandatory form which a SNOD must take, and after the pro se petitions, hits them with the real thing. By the time Tax Court has told the self-represented that the bombardment was a dud round, and therefore tosses their petition, the magic ninety days has run on the real thing, so tough luck.

I think my readers know I’m no fan of sneaky.

So here’s Alvin Hines, Docket No. 19440-16S, filed 10/21/16.

Apparently IRS muffed the mailing address for the SNOD, and wants to claim no jurisdiction for want of valid SNOD.

Ch J Iron Fist tips off Alvin.

“Petitioner is also reminded that if he should receive a new and properly addressed statutory notice of deficiency…, he should (within 90 days of the date of the notice) file a new and separate petition, in order to protect any statutory rights to dispute that notice.” Order, at p. 1.

Thanks, Ch J Iron Fist. This should be SOP. And how about the filing fee?


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