In Uncategorized on 05/10/2022 at 15:35

Oh Yes You Can

Hallmark Research Collective, Docket No. 21284-21, filed 5/10/22, wants a vacation, so Ch J Maurice B (“Mighty Mo”) Foley sends ’em off to Judge David Gustafson, with instructions to oblige the Hallmarks with an order disposing of their Rule 162 motion. While Ch J Mighty Mo wrote the order from which the Hallmarks seek relief, he may well not wish to reconsider it.

The Hallmarks were a day late and a lot more than a dollar short with their petition from a SNOD, when Ch J Mighty Mo gave them the right-about-face back on 4/1/22. The Hallmarks wanted equitable tolling.

Of course, Boechler was still at 8 Cir, which held the 90-150 day cutoff was jurisdictional, when Ch J  Mighty Mo tossed the Hallmarks. So I didn’t blog the 4/1/22 order then, as there was nothing new.

Enter the Supremes, kicking off a massive silt-stir. See my blogpost “Ya Can’t Make This Stuff Up – Part Deux,” 4/29/22.

My prediction from a couple weeks ago (hi, Judge Holmes) is coming true. I claim no great prescience. This sort of thing had to follow as night follows day. And of course this is but the start.

I forbear to comment on the current Supreme Court bench and its apparently endless talent for creating chaos in the realm of tax collection. This is a non-political blog, of course. But I have commented extensively elsewhere on the Court’s ability to create chaos everywhere else.


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