In Uncategorized on 05/08/2017 at 13:50

“My Well of English Seems To Be Permanently Defiled”

Last week I filled in a blogpost with seventy-year-old British slang. Today I can only say “Whassup wit’ that?” This remark has to be completely obsolete by now, but I am without alternative.

Here’s that Obliging Jurist Judge David Gustafson being obliging as usual.

An example. Woodie H. Powell, Docket No. 22250-16L, filed 5/8/17. And there are two orders here with the same docket number.

In the first, Woodie wants a Wagner toss of his CDP petition, IRS gives anihil obstat and Judge Gustafson obliges.

But within ten days, IRS is back with a Rule 162 vacation, and it’s Woodie’s turn to consent, so the toss is out and Woodie’s petition (and case) is back in.

OK, might be a mere “whoops!”


See Precision Plumbing of Mississippi, Docket No. 5881-16L, filed 5/8/17; see also Charles E. Patton & Linda D. Patton, Index No. 30250-15L, filed 5/8/17; see also Franklin Dyche & Elizabeth Dyche, Docket No. 13555-26L, filed 5/8/17; see also Gregory Courtney, Docket No. 8895-16L, filed 5/8/17; see also Ronald T. Atkinson, Docket No. 25512-15 L., filed 5/8/17; see also Cook & Riley, Inc., Docket No. 32051-15L, filed 5/8/17; see also Arthur Jenkins, Docket No. 1058-16L, filed 5/8/17; see also Jeff Jones, Docket No. 30460-15 L, 5/8/17. No links; you can check this out for yourselves.

Nine (count ‘em, nine) cases, all Wagnerized by motion made the same date and order issued same date, and all unWagnerized by motion made the same date and order issued same date.

Was Wagner overruled, and did I miss it somehow? Did IRS claim a bunch of deficiencies or non-assessables were paid, when they weren’t? Was there a Rev. Proc., Rev. Rul., Notice, statutory enactment or executive order that slipped by while I wasn’t looking?

I crave enlightenment.

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