Attorney-at-Law

PLAYING AN OLD GAMBIT

In Uncategorized on 06/10/2022 at 17:28

William R. Rohlf and Kristin A. Rohlf, et al., Docket No. 7395-22, filed 6/10/22, find themselves confronted with an old gambit I thought had long since been discredited.

Bill and Kris timely file two (count ’em, two) petitions for the same SNOD. One was signed, the other wasn’t, but neither was accompanied by the sixty George big blind. IRS, maybe playing an old gambit (see my blogpost “Another Taishoff ‘Oh, Please,’ 9/24/14)  tried to close the signed petition file on grounds of duplication, setting up a quick toss for unsigned petition, but Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan straightens it out, and closes the unsigned.

IRS has of course filed motion for leave to file an answer out of time (that’s late in FedCourtspeak) and lodged (that’s filed but not filed, ditto) an answer in both.

Since Bill and Kris petitioned 3/21/22, they still have a couple days (hi, Judge Holmes) to ante up the sixty Georges before the Section 6213(a) 90-day cutoff (assuming the Supremes haven’t monkeyed with that also). So what about Ch J TBS’ sixty days for sixty Georges (see my blogpost thus entitled).

Ch J TBS gives Bill and Kris until 7/5/22 to ante up or plead poverty.

Since it’s apparently open season on all Tax Court time limits, how about equitable tolling for the sixty Georges?

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