In Uncategorized on 08/09/2018 at 12:17

Ch J Maurice B (“Mighty Mo”) Foley certainly has claimed that title.

Yesterday he bounced a nonpayor and nonjuror (didn’t swear poverty) after a mere three weeks post-petition.

Today, he has a pro se partner other than TMP with a TEFRA FPAA small-claimer imperfectly petitioned. She gets the same three weeks to ante up with pleadings conforming to Section 6226 and Rule 241.

Otherwise, she too will be at risk.

I’m not saying Ch J Mighty Mo is wrong. Too many wisepeople try to use Tax Court as a temporary restraining order against the IRS by submitting junk to buy time.

Of course, having not seen the petition nor having any knowledge of the facts, I cannot suggest that Signet Interactive LLC, Ashley Paige Mathis, A Partner Other Than The Tax Matters Partner, Docket No. 15099-18S, filed 8/9/18, has anything but a bona fide claim.

But even some attorneys file less than letter-perfect petitions in TEFRA FPAAs. And the Ownership Disclosure Form (not filed in this case) baffles many who confront it.

All I can suggest is that a pro se in a small-claimer confronting TEFRA might get an extra week or two and the name of a LITC.

And wiseacres and wags, beware.


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