Attorney-at-Law

EXHAUSTION

In Uncategorized on 02/23/2018 at 14:54

I was nearly exhausted reading the back-and-forth between Michael J. Baumgartner & Keri A. Baumgartner, Docket No. 2670-16, filed 2/23/18, their trusty attorney, to whom I’ll hereinafter refer as “JC,” and IRS TCO and subsequent group manager.

Mike and Keri claim section 301.7430-1(f)(2), Proc. & Admin. Regs, lets them off the hook if they bypass Appeals before IRS folds. This is another Section 7430 legals, but Judge Nega isn’t dealing with justification.

No, it’s the old exhaustion-of-administrative remedies.

IRS is rather like the Pirates of the Caribbean when it comes to IRS’ Procedural Rules. They’re “guidelines,” ”aspirational goals.”

Besides, there were two (count ‘em, two) letters from the TCO and subsequent group manager that were in fact thirty-day letters, and Mike and Keri should have gone to Appeals.

Having elected not to go, the legals are off the table.

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 )

w

Connecting to %s

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

%d bloggers like this: