In Uncategorized on 11/16/2018 at 19:01

There are moments. When you talk yourself off the winning horse, and your spouse tipped the winner; when the remark that would have been brilliant at the dinner party comes to mind as you open your front door; and today, when the winged messenger of the Olympians brings the perfect title for a blogpost after you’ve posted.

Today’s title was “Hold ‘Em.”

Hold ‘em was an attorney who, he claimed, had never been cautioned or sanctioned in 36 (count ‘em, thirty-six) years of practice. But Judge Mary Ann (“She Who Eschews Cognomens”) Cohen yellow-carded him today for littering the Mobile, AL trial calendar with 42 (count ‘em, 42) cases over the last twelvemonth, all of which he moved to withdraw.

They were all petitions from CDPs, so dismissal on the eve of trial penalized no one but IRS, who Section 6330(e) estopped from collection activities, and the hard-laboring clerks and flailing datestampers at 400 Second Street, NW, who had more electrons to corral.

Remember, Wagner v. Com’r, 118 T. C. 330 (2002), said that withdrawing a petition from a CDP, unlike one from a SNOD, incurs no penalty.

So Hold ‘em did this 42 times, stymieing IRS for months.

I really should have taken a hint from George Bernard Shaw’s 1898 retelling of Der Ring des Nibelungen.

Hold ‘em is indeed The Perfect Wagnerite.


Leave a Reply

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

You are commenting using your 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: