We’re often the recipients of retailers’ offers to “Buy One, Get One Free,” acronymized to “BOGO.” Today Ch J Maurice B (“Mighty Mo”) Foley, zealous guardian of the “small court” purse, grabbing every available George for The Glasshouse Gang, won’t play that game.

Ricardo J. Perez, Donor, and Michelle L. Perez, Donor, Docket No. 20877-19, filed 9/21/20 “…filed a petition seeking to dispute notices of determination regarding the value of gifts for tax year 2012 issued to petitioners … and notices of deficiency for tax year 2014 issued to petitioners…” on the same day. Order., at p. 1.

We all know, as Ch J Mighty Mo man-‘splains to Ricardo and Michelle, and incoming trusty attorney, that each action needs a separate petition. Tax Court again is unlike every other Federal and State court I know of, where one can allege multiple causes of action or bases for relief, either collectively or alternatively.

Here we have a declaratory judgment action regarding gift valuation, and a separate action for redetermination of a SNOD, joined at the cliché.

So what to do?

Sever, of course. Leave the first Docket No. for the declaratory judgment and create a separate Docket No. for the SNOD.

And get another sixty Georges for the second Docket No.

BOGO is No Go for Ch J Mighty Mo.