The words of an Authority even more exalted than Judge Nega echo through his order in Alan L. Davis & Deborah D. Davis, Docket No. 13791-18, filed 7/17/20. Seems Al & Deb maybe so petitioned a SNOD, having something to do with Clean Energy Systems.

But the envelope wherein the petition arrived bore a return address other than Al’s & Deb’s, namely, that of Management Concepts, PLC. And when Al & Deb moved to dismiss same, the signatures on the motion didn’t match those on the petition. Of course, you can’t dismiss a timely petition from a SNOD without handing IRS a win on all counts.

But doesn’t this all sound a wee bit familiar? If not, see my blogpost “Eh Bien, Voila Au Moins Qui N’est Pas Banal – Redivivus,” 6/4/19.

Looks like Carl Rex Olson, honcho of Management Concepts, PLC, whence came the dubious petition in this case, is at it again.

Judge Nega doesn’t mention Judge Buch’s takedown of Carl Rex, particulars of which can be found in my blogpost hereinabove cited. But he did find the same Federal statute to use in a footnote, just like Judge Buch.

“It appears that Mr. Olson is no stranger to this Court and we warn him that if he continues to engage in similar conduct in the future, the Court would strongly consider referring him to the U.S. Department of Justice for prosecution.” Order, at p. 3. (Footnote omitted, but here it is).

“18 U.S.C. sec. 1001 generally makes it a crime to knowingly and willfully submit to a court ‘any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry.'” Order, at p. 3, footnote 3.

Of course, Al’s & Deb’s non-petition is tossed because not signed by petitioners.

But may I most respectfully suggest that, once the lights go on again all over the world, Judges Nega and Buch get together in the Tax Court Judges’ cafeteria, over a cup coffee and a piece pie (hi, Judge Holmes), and sort out how to handle Carl Rex.