In Uncategorized on 03/07/2017 at 14:13

Why bother with statutes and rules, and jurisdiction, and all that stuff, when Tax Court is cheaper than a specialist co-pay?

So back again come Annamalai Annamalai & Parvathi Sivanadiyan, Docket No. 22317-16L, filed 3/7/17.

Back in 2015, Anna & Par wanted Judge Cohen to get one or both of them out of “the Segregation Hole,” wherever that was. Well, Judge Cohen couldn’t help. Jurisdiction, y’know. See my blogpost “I’d Do Anything For Love,” 9/14/15.

Nothing daunted, but apparently released from the aforesaid Hole, Anna & Par wanted IRS’ motion for entry of decision granted, but seemed think that meant they were paid up on the $98K of tax and penalty they owed. Well, Judge Cohen told them they weren’t. See my blogpost “The Two-Adviser Rule,” 6/23/16.

So Anna & Par petitioned anew, apparently from a SNOD. Except Anna & Par attached no SNOD to said petition, and IRS answered that there was no SNOD.

Anna & Par, resourceful as ever, came up with a really interesting, if unsuccessful, ploy.

“In their response to respondent’s motion to dismiss, petitioners do not address respondent’s jurisdictional allegations. Rather, petitioners assert that they served respondent with requests for admissions to which respondent has failed to respond. Accordingly, petitioners contend that facts in their favor have been conclusively established, and they are entitled to a judgment as a matter of law.” Order, at p. 2.

Sorry, Anna & Par, you’re out again. And this time Ch J L Paige (“Iron Fist”) Marvel delivers the bad news.

“However, if this Court does not have jurisdiction, we cannot reach the merits of a case.” Order, at p. 2.

But I must give Anna & Par a Taishoff “good try, third class.”


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