In Uncategorized on 01/13/2018 at 15:21

The words of a much greater writer than I give me a title to my blogpost about Michael Sean Greenewald, Docket No. 25719-17, filed 1/12/18. I’m a day late, being away from home but with Sir Andrew brought to me by a principal in a Big Four Tax firm.

Michael Sean petitions a batch of SNODs and NODs for taxable years from 2004 to 2017. He states simply “I have never received a notice of deficiency or a notice of determination for the years 2004 thru (sic) 2017.” Order, at p. 1.

IRS responds with a Rule 51 motion for a more definite statement. Much more usual is the motion to dismiss for failure to state a claim on which relief can be granted. So I blog this one.

Ch J L Paige (“Iron Fist”) Marvel finds Michael Sean’s statement definite enough to send IRS off to search its records to see if it sent anything, and to make appropriate motions thereafter.

This is the good-mannered response to IRS’ motion. It is much better than “What part of ‘he never got nothing’ don’t you understand?”


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