Back in March, when then-Ch J Maurice B (“Mighty Mo”) Foley promulgated his stylistic emendations to the Tax Court Rules of Practice and Procedure, I greeted one of then-Ch J. Mighty Mo’s changes with real enthusiasm.

See my blogpost “A Chip Off the Old Rock,” 3/23/22.

I did expect it would take time for Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan to review all the learned commentary, which my colleagues would provide her without stint. And the deluge of petitions from the COVID era, to say nothing of the need to adapt the Court to its Post-COVID architecture, would occupy much of the Ch J’s attention.

But all that said, there is one proposed amendment that needs no debate. That is Proposed Rule 20, and its sibling, the new Form 6, Ownership Disclosure Form.

Happily, the number of orders directing corporatists to file the form, or to fill it out properly and file it, is minuscule. Of the 484 (count ’em, 484) orders issued today, only four were orders relating to Form 6, a matter of 0.826%.

So, while the other Rules may abide our question, may I respectfully suggest that Ch J TBS is free to adopt this one?