In Uncategorized on 12/14/2021 at 16:10

Generally, we lawyers have inquiring minds. It’s not enough to know what, or who, or when; before all, it is to know why. That is true, even if “why” is totally irrational. Once we know why, we can deal with the consequences.

I’ve mused before on this my blog why Form 6 Ownership Disclosure Statement is such an obstacle to entity petitioners. It is a single-page form. It asks only three (count ’em, three) questions. I dare say in 95% of the petitions filed in US Tax Court, the answer to all three questions is “NONE.”

Yet today, 12/14/21, a very special day in our family, I see no fewer than six (count ’em, six) orders giving petitioners more time to file Form 6. The petitioners are all conducting, or, I assume, assert they are conducting, or have in the year(s) at issue conducted, business operations to the extent that principals thereof had to know how to read and write at least well enough to graduate from lower school.

I have in the past suggested modifying Form 6, by adding the words, in bold-faced capital letters “YOU CANNOT LEAVE THIS FORM BLANK; IF “NONE” WRITE “NONE”. See my blogpost “Even Good Accountants,” 3/25/19.

But no; the form, last modified almost ten years ago, retains its 1 Corinthians 1:23 characteristics.

And it doesn’t provide for signature by post-TEFRA representatives.


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