In Uncategorized on 04/02/2019 at 15:17

The Ogden Sunseteers even reopen cases without letters, and the question of remand from Tax Court (does remand imply a Tax Court order to IRS to commence a proceeding against the target when IRS has decided not so to proceed?) remains unanswered.

See my blogposts “A Hotly-Burning Question What Has Swept The Continent – Redivivus,” 7/28/17, and “Remand? You Can Whistle For It,” 1/31/18.

But Stanley H. (“Stan the Man”) Epstein, Docket No. 28731-15W, filed 4/2/19, star of the first-above-cited blogpost, is fighting IRS’ motion for summary J, even though he got a new letter from the Ogden brigade (apparently without remand, so the hereinabove referred to question remains unanswered) and timely petitioned same.

Judge Albert G (“Scholar Al”) Lauber has this one, and wishes Stan the Man to unconfuse him.

“In his response petitioner shall address respondent’s argument that this case is moot in light of the IRS’ decision to reopen his claim, the IRS’ issuance of a final determination with respect to the reopened claim, and his filing at docket number 2965-18W of a petition to challenge the IRS’ determination with respect to his reopened claim.” Order, at p. 1.

So apparently IRS can volley new determinations even when the old ones (which may be multiplex) have been petitioned and are before the Court. The epistolary bombardment goes on and on.

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