Attorney-at-Law

BEST OF LUCK

In Uncategorized on 05/05/2017 at 14:15

The Big Bangers at 400 Second Street NW really were working overtime yesterday, 5/4/17. Not one single order of 125 (count ‘em, 125) issued that date was worthy of a blogpost.

So I did what I have often been encouraged or directed to do: I said (and wrote) nothing.

But today there appears an item that at least satisfies the criterion that General Galieni set so long ago as the Taxis of the Marne brought up reinforcements: “Eh bien, voila au moins ce qui n’est pas banal!”

It’s Estate of James P. Keeter, Deceased, Garry L. Holton, Jr., and Thomas W. Schaefer, Co-Executors and Julie L. Keeter, Docket No. 6771-16, filed 5/5/17.

You remember the sad tale that even in death the claws of TEFRA still grip the late James P. See my blogpost “Inside, Outside – Redivivus,” 4/3/17.

Well, Ch J L Paige (“Iron Fist”) Marvel wanted the Co-ex’rs and Julie to join IRS in briefing whether the various penalties are computational, in light of Woods, therefore not subject to deficiency jurisdiction as nonassessable.

The Co-ex’rs and Julie respond.

“…petitioners filed a Motion for Leave To File a Short Brief which the Court will recharacterize as petitioner’s letter. In that letter petitioner state they wish to be given leave to file a short brief as to why their pending motion to restrain the tax assessment made against them… should be sustained even if the Court finds that it lacks jurisdiction in this matter.” Order, at p. 1.

I give counsel for the Co-ex’rs and Julie a Taishoff “Best of luck with that one,” second class.

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