Despite its cutesy name, the so-called PATH Act has given rise to many changes, and today Ch J L. Paige (“Iron Fist”) Marvel has a reminder for IRS. Counsel should read the rules.

It’s Robert Watson, Sr., Docket No. 21516-16S, filed 11/1/16.

RW wants interest abated, but IRS says “we don’t got no NOD.” Or words to that effect.

Ch J Iron Fist issues her suggestion aforesaid thus:

“The Court’s Explanation to Rule 280, as amended on an interim basis, states as follows:

Explanation

Section 421 of the Protecting Americans from Tax Hikes Act of 2015, Pub. L. 114-113, Stat., amended Code section 6404(h) to provide that a taxpayer may petition the Court for an abatement of interest if the taxpayer files a claim for interest abatement with the Internal Revenue Service and the Commissioner fails to issue a final determination on the claim within 180 days after the claim was filed. This amendment is applicable to claims for abatement of interest filed with the Internal Revenue Service after Dec. 18, 2015. Rule 280 is amended on an interim basis to reflect the amendment to Code section 6404(h).” Order, at p. 2.

And Ch J Iron Fist obligingly prints the interim rule in extenso, so all hands can do a Habakkuk 2:2. And IRS can tell Ch J Iron Fist if he did.

Meantime, RW, dig through your files and see what you did. And when.

Everybody else, update your forms of pleading.