Judge Travis A. (“Tag”) Greaves is laconic. He wastes no words in tossing Vahik Aghadjanian, 2020 T. C. Memo. 155, filed 11/16/20, for being three weeks (actually 23, count ’em, 23 days) late with his petition. IRS sought summary J, and Vahik didn’t respond.

My readers, counting the days until Tax Court shuts down its daily delivery of press releases, orders and opinions, will doubtless ask “Why does this need a T. C. Memo.?” In the ordinary course a simple order would do.

Except.

This is a Section 7623 Whistleblower case. And it took the Ogden Sunseteers four (count ’em, four) years to reject (or maybe deny; Judge Tag doesn’t say) Vahik’s claim. 2020 T. C. Memo. 155, at p. 2. Don’t strain yourselves, chaps.

Anyway, Vahik is out. All Judge Tag has to say is that he was late. True, Vahik never raised Myers or anything else. And a Rule 161 probably won’t help, as there’s no new facts or law.

But if Vahik reads this (a most unlikely occurrence), he should read my blogpost “For Whom the Equitable Tolls,” 4/10/20. And maybe so consider a Rule 161. Fast.

Takeaway- Those who need this won’t read this, and those who read this don’t need this. But raise any cognizable issue every time. You won’t get if you don’t ask.