In Uncategorized on 12/20/2021 at 11:03

A commenter on my blogpost “From My Scrapbook – 12/16/21,” of even date therewith, suggested that Ch J Maurice B (“Mighty Mo”) Foley had gotten the third person singular personal pronoun wrong for Amaka L. Ezan, Docket No. 30234-21, filed 12/20/21.*

Commenter asserted that “Amaka” is “primarily a female name of African – Nigeria origin that means Precious.” I have not independently verified this assertion, so it is offered for the fact that it was asserted, not for the truth of its content.

However, today Ch J Mighty Mo seems to have been right, although applying Cohan to get there.

“… petitioner filed a First Amended Application for Waiver of Filing Fee. However, like petitioner’s initial application, the amended application is captioned in the name of “Joel Landry Ezan”. Order, at p.1.

Alas, despite the time-honored benevolence I invoked on Amaka/Joel’s behalf in my hereinabove-cited blogpost, Cohan overrides A Christmas Carol, and the Court may bear heavily upon the taxpayer/petitioner “whose inexactitude is of his own making.”

And that goes beyond pronouns, even to filing fee.

“As previously noted in the Court’s Order served December 16, 2021, denying petitioner’s initial application, that caption does not match this case. Consequently, the Court is unable to process the amended application. See Rule 23(a)(1), Tax Court Rules of Practice and Procedure.” Order, at p. 1.

So pay up, Amaka/Joel.

*Amaka L. Ezan 30234-21 12 20 21


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