In Uncategorized on 11/22/2019 at 18:17

Reference is made to my blogpost “Another Taishoff ‘Oh Please,’” 2/24/14. But this time IRS gets it right, and tips off Ch J Maurice B (“Mighty Mo”) Foley to his miscue.

Dmitriy Tsibulskiy, Docket No. 15660-19, filed 11/22/19, has a resuscitated docket no., because Ch J Mighty Mo sua spontedly closed his present one (15660-19) as duplicative of the earlier one (2456-19).

IRS, filing a response as directed in the earlier one (2456-19), pointed out there was no NOD for any of the four (count ‘em, four) years that Dmitriy petitioned, and he was too late for the SNOD they had issued back in 2010. By about nine (count ‘em, nine) years.

But the latest SNOD (one for one of the four years Dmitriy petitioned) was issued before Dmitriy’s petition.

Dmitiry is timely for that year, if the heretofore-duplicative docket no. returns to life.

So Ch J Mighty Mo vacates his earlier order, closes the earlier docket, and resuscitates the later one.

And IRS can file “an appropriate jurisdictional motion” (Order, at p. 2) in the current case.

Ch J Mighty Mo is quick off the mark, but maybe this time too quick.

And Elisa M. Gonzalez, Esq., of OCC, gets a Taishoff “Good Going, First Class.”



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