Attorney-at-Law

TOO LATE THE PHALAROPE

In Uncategorized on 03/14/2017 at 15:48

For this snowy day’s sermonette, I take my text from Alan Paton’s 1953 novel of “terror and remorse,” emotions that sometimes accompany Tax Court opinions and orders.

Y’all recall the blessed communion, fellowship divine, of private delivery services given the Commissionorial nod by Com’r John (“Kosy”) Koskinen, apparently the still-unimpeached honcho at snow-blanketed 1111 Constitution Ave, NW.

Well, Frank Squillo, Jr., Docket No. 2186-17S, filed 3/14/17, used one of the right ones.

IRS wants to toss Frank Jr. for late filing. And IRS’ counsel seems to think that Ch J L Paige (“Iron Fist”) Marvel or one of her minions told him that Frank Jr’s petition hit 400 Second Street, NW in an envelope with a USPS postmark a day late and more than a dollar short.

Negatory, responds Ch J Iron Fist.

“Contrary to respondent’s suggestion in paragraph 4. of his motion, the Court did not inform respondent that the shipping envelope bearing the petition bears a U.S. Postal Service postmark dated January 26, 2017.” Order, at p. 1.

That’s because Frank Jr used UPS Next Day Air Saver, one of the blessed.

So he was saved. Or maybe not.

In today’s episode, Ch J Iron Fist tells IRS’ counsel to supplement his motion to toss with the electronic printout info from UPS showing when they got their paws on the magic envelope.

See Notice 2016-30, 2016-18 I.R.B. 676, which gives the latest hot tips on the blessed ones and how to track these stars in their courses.

Moreover, Ch J Iron Fist obligingly gives IRS’ counsel the UPS tracking number.

Well, I tried it just now my own self. If I got it right, it don’t look too good for Frank Jr.

 

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