One can be intelligent, and yet have no idea how limited is the jurisdiction of the United States Tax Court. Compared to the broad powers of the Art IIIs, pore l’il ole USTC, an Art I stepchild, is a mere “bruised reed, and a dimly-burning wick,” in the words of a much more exalted authority even than Judge Joseph W. Nega.

Here’s Intelligent Transportation & Monitoring Wireless LLC, Warren C. Havens, Tax Matters Partner, Docket No. 19514-17, filed 6/2/21.

Looks like TMP Warren is tapped out, and the Intelligent piggybank has been wrested from his hands. Nevertheless, gotta pay the lawyers.

So TMP Warren files a “Motion for Leave to File Petitioner TMP’s Motion for an Order to the Taxpayer-LLC’s Receiver, Susan Uecker, to Release Taxpayer-LLC Funds to Enable the Tax Matters Partner to Conduct this Case.” Order, at p. 1.

Judge Nega just denies the motion without explanation.

But because I’m an obliging sort, and a general busybody, here it is.

TMP Warren, Tax Court has no jurisdiction over Taxpayer-LLC’s receiver. Receivers are governed by the law under which they were appointed and are subject to the orders of the judge who appointed them. Tax Court has no jurisdiction to appoint a receiver. Tax Court has no jurisdiction to order a receiver to do anything.

The American infatuation with our judicial system, combined with a total misunderstanding of what that system can do, leads to smh, as the texters say.