In Uncategorized on 07/02/2019 at 16:25

As it was in the beginning, this shall remain a non-political blog. But Shapat Nabaya, Docket No. 7207-19, filed 7/2/19, seeking to remove from public view his SSAN, which he thriftlessly strewed all over his petition from an alleged NOD, has gifted Ch J Maurice B (“Mighty Mo”) Foley with a motion thus entitled.

Ch J Mighty Mo, wasting no time, doesn’t bother recharacterising Shap’s motion, but tells him to send in an amended petition in idem verba (as my already-on-their-second Grey-Goose-V&T colleagues would say), erasing only TINs.

Of course, there remains the question whether there was in fact a NOD from a CDP, from which Shap timely petitioned.

So let IRS and Shap send in copies of every document upon which each relies to establish (or disestablish) jurisdiction.

Though pleadings may be liberal, jurisdiction is another story.

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