Attorney-at-Law

THE DILATORY PETITIONER’S TOOLBOX

In Uncategorized on 12/29/2017 at 16:03

I was truly disappointed in STJ Armen, The Judge With a Heart, when he sent off poor late-filing Amy L. Goline, with an off-handed cite to McCormick and no mention of anything else; see my blogpost “Ya Gotta Have Heart,” 11/9/17.

Well, today Ch J. L Paige (“Iron Fist”) Marvel lays out the full contents of the toolbox for Charlotte Marie Strickler, Docket No. 18477-17S, 12/29/17.

Charlotte Marie was two days late and a lot more than a dollar short, because she used an unblessed variant of FedEx. Remember that only those sanctified versions of the Black-and-Purple gang slide under the Section 7502 mailed-is-filed tag. FedEx Express Saver saved Charlotte Marie nothing, as it wasn’t among the “blessed communion, fellowship divine.”

So Charlotte Marie is tagged “out.”

But Ch J Iron Fist manifests the kindliness of spirit worthy of this season, and counsels Charlotte Marie of other shelter than the Inn at 400 Second Street, NW.

“However, although petitioner may not prosecute this case in the Tax Court, petitioner may continue to pursue administrative resolution of the tax liability for 2015 directly with the Internal Revenue Service, possibly by way of a request for audit reconsideration or by filing an amended income tax return. Another remedy available to petitioner is to pay the tax, then file a claim for refund with the Internal Revenue Service. If the claim is denied (or not acted upon within six months), petitioner may sue for a refund in the Federal district court or the U.S. Court of Federal Claims. See McCormick v. Commissioner, 55 T.C. 138, 142 (1970).” Order, at p. 3.

STJ Armen, please copy.

Advertisements

Leave a Reply

Please log in using one of these methods to post your comment:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

This site uses Akismet to reduce spam. Learn how your comment data is processed.

%d bloggers like this: