In Uncategorized on 11/07/2017 at 16:37

More than once on this my blog I’ve announced that I’ll never be a Tax Court judge. I wasn’t on law review. I wasn’t a member of the Order of the Coif. I never clerked for any judge. I never worked for a white-shoe law firm or Big Four CPA, much less made partner. I never worked in the Office of IRS Chief Counsel, or anyplace in Treasury.

I’m just an old-time, beaten-up, beaten-down, single shingle “general practitioner with very limited experience and mediocre qualifications,” as “the best and wisest man” John H. Watson ever knew put it.

So I must accept my lot in life, with a sly grin that I am not reduced, as Ch J L Paige (“Iron Fist”) Marvel, who has all the qualifications and experience needed for Tax Court Boss, and then some, to the following.

Daniel Ray Hippensteel, Docket No. 18584-17S, filed 11/7/17.

“In that petition, petitioner elected to have this case conducted under the Court’s procedures for small tax cases, pursuant to Internal Revenue Code section 7463. …respondent filed his Answer to the petition. …petitioner filed a Reply To Answer. Generally, a reply to an answer is not to be filed in a small tax case, unless otherwise directed by the Court. See Rule 173(c), Tax Court Rules of Practice and Procedure. Accordingly, we will recharacterize petitioner’s reply.” Order, at p. 1.

Well, if it’s not to be filed, does it get tossed? Or something else?

Daniel Ray’s Reply To Answer (hold your breath) “…is recharacterized as a Letter.” Order, at p. 1.

I’m sure I couldn’t possibly manage that.


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