In Uncategorized on 12/27/2021 at 13:04

My colleague Peter Reilly, CPA, noted that the docket number of the first petition filed in calendar 2021 was number 35101-21, not 35000-21. Therefore, he asserted, Sara Elizabeth Schweigert & Marcus Schweigert, Docket No. 35000-21, served 12/23/21, did not file the thirty-five thousandth petition. Thus, my claim that 35,000 had been reached (see my blogpost “A Christmas Present,” 12/24/21, and the comments thereto) was premature.

I accept, without making an affirmative finding, that Mr. Reilly is correct.

So today I offer Maria Esnaola, Docket No. 35101-21L, filed 11/12/21*, in place and stead of the Schweigerts.

My August 30 prediction was definitely in the money. Now who’s running a pool on the total number of petitions filed this year?

*Maria Esnaola Docket No. 35101-21

  1. Of course Ms. Esnaola is also the petitioner in 34826-21L. So are we counting petitions, or petitioners? Should we wait to make sure that 35101-21L is not just a duplicate?


  2. Tax Court did not itself distinguish between petitioners and petitions. Both of the press releases issued by Public Affairs referred to the number of petitions filed. Many of these may have been letters or other communications not in proper form, and some no doubt are duplicative. There have been cases where the mailing of a money order for the filing fee, without more, was deemed a petition.See my blogpost “Show Me the Money,” 11/13/13.

    So my point remains: 35,000 petitions.


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