The United States Tax Court website needs a pop-up banner: LIMITED JURISDICTION – NOTICE OF DEFICIENCY OR NOTICE OF DETERMINATION ONLY: CAN’T HELP WITH ANYTHING ELSE

This would have saved James D. Semelroth & Carol E. Semelroth, Docket No. 18750-22S, filed 11/8/22, sixty dollars and almost three months’ time. All Jim & Carol had to show Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan was “a voluminous collection of copies of various IRS communications in the form of other notices and letters that related to such payments or lack thereof.” Order, at p. 1.

“Such payments” were the so-called economic stimulus payments, which Jim & Carol claim they never got.

What’s missing from this picture? A SNOD or NOD.

Replying to IRS’ motion to toss for want of jurisdiction,”(P)etitioners then went on to highlight an extensive saga of efforts to resolved the matter administratively with the IRS, including attempts to request assistance from the Taxpayer Advocate Service and the U.S. Congress. Conversely, petitioners did not allude to or attach any further notices from the IRS that could bear upon the jurisdictional query before the Court.” Order, at p. 3.

Ch J TBS provides the usual boilerplate enumeration of Tax Court’s circumscribed jurisdiction, with copious citation to the statutory fetters wherewith Congress has thus bound the “small court” Prometheus to the rock at 400 Second St., NW.

I can’t say whether Jim & Carol find this essay worth the sixty bucks that vanishes when their petition is tossed, despite Ch J TBS’ sympathies for their plight. “…while the Court is sympathetic to petitioners’ situation and understands the challenges of the circumstances faced and the good faith efforts made, the Court on the present record lacks jurisdiction in this case to review any action (or inaction) by respondent in regard to petitioners’ taxes. Congress has granted the Tax Court no authority to afford any remedy in the circumstances evidenced by this proceeding, regardless of the merits of petitioners’ complaints.” Order, at pp. 3-4.

On this day of all days, in the face of an almost overwhelming temptation, I must eschew political comment. Adding my puny voice to the ultimate storm now raging could only provoke and not calm. So I shall simply state that any government that fails to respond to the perceived needs of its populace … but you know the rest.