Attorney-at-Law

MY NOTEBOOK 8/25/20

In Uncategorized on 08/25/2020 at 13:11

To begin with, a “huh?” more particularly bounded and described as a query. IC Improvements, LLC, Michael J. Luciano, Tax Matters Partner, Docket No. 4669-20S, filed 8/25/20. IC moves to dismiss, IRS doesn’t object, so Ch J Maurice B (“Mighty Mo”) dismisses, saying nothing else. But what about Section 7459(d)? The “L” suffix is missing, as is the obligatory citation to Wagner, so this isn’t a CDP. Likewise, no “W” suffix or citation to Jacobson, so it isn’t a blower case (assuming an LLC can maintain a whistleblower case; see Section 7623(b)(1)). Therefore, why no entry of decision for the amount stated in deficiency, or statement that from the record Ch J Mighty Mo can’t compute what the decision should be?

Next, STJ Diana L (“The Taxpayer’s Friend”) Leyden has four (count ’em, four) dubious Section 6751(b) Boss Hosses. Donald Bound and Frances Bound, Deceased, Docket No. 18743-19S, filed 8/25/20, has an unsigned CPAF dated after the Letter 915, 30-day. Same Michelle Y. Love, and William Love III, Docket No. 16713-19S, of even date therewith. IRS claims Joseph A. Albright and Elizabeth Albright, Docket No. 1709-20S, filed 8/25/20 never responded to the 30-day, so no IRS employee was involved, thus the chop was electronically computed. Ditto Michael Walter Brown and Gloria E. Brown, 1485-20S, filed 8/25/20. STJ Di wants the 30-day and the Revenue Agent Report. Looks like STJ Di will corral the Boss Hosses.

Finally, it’s truly an ill wind that blows no one any good. If the COVID-19 disaster brings us viable teletrials, then no more time will be wasted telling people with deficiencies north of $50K, who seek venue in localities reserved for small claimers, to look elsewhere. With teletrials, geography is irrelevant. Now if only there were a way for the public to observe teletrials, as required by Sections 7458 and 7461….

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