My four-thousandth (count ’em, four-thousandth) blogpost since I began this enterprise in December, 2010, features a prediction come to pass.
See my blogpost “26822-21,” 10/15/21.
A colleague e-mailed me the following this afternoon: “Lew, I know you were watching for a 32000 docket number in 2021. I just received 32052-21 this afternoon!”
Many thanks, Lyle! And good luck with the case!
Roll on the next four thousand posts!
32000 was served today — but the case was filed October 5. If a petition is received in December but not processed until January, is it assigned a -21 or -22 number?
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Mr Kamman, you are the second person who addressed that question to me today. I must unhappily respond to you as I did to the other: an excellent question, but you have addressed it to the wrong person. I do not know the answer. You might wish to ask Diane Servoss, Esq., the Chief Clerk of the Tax Court.
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I found the docket for Case 15000-20. Or, as the Tax Court website calls it, 15000-20SL. An amended petition was filed so maybe an L case turned into an S case. Anyway, it was received December 28, 2020, but not served until March 4, 2021. So apparently, at least for last year, they kept assigning 2020 numbers until all the petitions received that year were processed.
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It’s of course possible that the amendment reflected a reduced amount at issue below $50K as the result of a paydown, thus gaining small-claimer status. This tactic is useful when the amount at issue above $50K is sufficiently small, and the tactical advantages sufficiently great, to warrant employing it.
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Whether the current docket assignment protocols will continue into 2022 is a question which I cannot answer.
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