In Uncategorized on 12/31/2019 at 16:43

Tax Court is closing out the year 2019 on a distinctly diminuendo note. No opinions or designated hitters.

So your blogger is thrown back on an old theme, repeated again by Theodore Lee Croker, Docket No. 9070-18S, filed 12/31/19.

The last date for Theo to petition was May 7, 2018. And he did. Only his petition got to USTC on May 9. And that’s too late.

Theo was, of course, pro se. Theo used FedEx Express Saver. We all know that FedEx Express Saver is not one of the “blessed communion, fellowship divine,” blessed by the Com’r per Notice 2016-30, 2016-18 I.R.B. 676.

See my blogpost “The Grating Roar of Pebbles,” 12/6/18. Not every service offered by FedEx, UPS or DHL qualifies for Section 7502 “mailed-is-filed” treatment.

As I said a year ago, “(T)he statutory and regulatory grand slalom through which any PDS must go to certify one of its services … guarantees that none of the Big Three will bother to add any service to the blessed communion. Why should they spend one minute or one cent on a process that will add nothing to their respective bottom lines? If the hapless pro se or ill-informed practitioner uses the wrong option, the PDS got paid, and xin loi about the toss. The only injured parties are the pro sese with meritorious claims that get tossed on a ridiculous hyper-technicality.”

And their cheapo services are certainly not worth adding, when only their premium services are IRS-qualified.

Happy New Year.

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