Back on 11/17/20, I pointed out that a petitioner couldn’t settle while Dawson’s Creek was in flood. See my blogpost “Ya Can’t Even Settle,” of even date therewith, as my expensive colleagues would say.

Turns out petitioner and IRS did settle right after the New Year. But nobody knows what they settled, because their stipulated decision is not available on the new, improved (come on, guys), jim-handy DAWSON website.

It’s Section 7461 time again.

And don’t tell us to surry down to the stoned soul picnic on Second Street in The Wannabe State, as the doors are still locked thereat.

If Ch J Maurice B (“Mighty Mo”) Foley can spare a minute from ordering petitioners to pony up the sixty George big blind (or seek waiver therefrom), and send in wet-ink original amended petitions that state something like a claim based upon which relief might be granted, I suggest he adopt our New York Rule 216.1.

Here’s the text: “(a) Except where otherwise provided by statute or rule, a court shall not enter an order in any action or proceeding sealing the court records, whether in whole or in part, except upon a written finding of good cause, which shall specify the grounds thereof. In determining whether good cause has been shown, the court shall consider the interests of the public as well as of the parties. Where it appears necessary or desirable, the court may prescribe appropriate notice and opportunity to be heard.

“(b) For purposes of this rule, ‘court records’ shall include all documents and records of any nature filed with the clerk in connection with the action. Documents obtained through disclosure and not filed with the clerk shall remain subject to protective orders as set forth in Rule 103.”