Attorney-at-Law

40 YEARS

In Uncategorized on 08/27/2019 at 13:23

The race to the back in the New Gambit stakes goes on apace. See my blogposts “I’m Beginning to See the Light,” 4/9/18, and “The Light at the End,” 8/20/19.

Today Frank M. Dartee, Docket No. 3792-18, 8/27/19, goes for the record…forty (count ‘em, forty) years, in one petition.

Ch J Maurice B (“mighty Mo”) Foley tells the story.

“Petitioner seeks review of purported notices of deficiency and notices of determination concerning collection action allegedly issued to petitioner for taxable years 2000 through 2018. On April 11, 2019, respondent filed a Motion for More Definite Statement Pursuant to Rule 51. On August 5, 2019, petitioner filed an Amended Petition seeking review of purported notices of deficiency and notices of determination concerning collection action issued to petitioner for taxable years 1979 through 2018.” Order, at p.1.

Ch J Mighty Mo, in a more mellow mood than is his wont, tells IRS to forget about a more definite statement from Frank, but to look and see whether there is anywhere to be found either NOD or SNOD issued to Frank for any of those years. Then tell Ch J Mighty Mo whether there is anything that would confer jurisdiction.

Is there a Section 6673 on the horizon?

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