Hence Rule 155

I blogged Tax Court as preparer years ago, but that sort of service faded into distant memory. I also blogged petitioners who tried to turn Rule 155 beancounts into Rule 161 reconsids or Rule 162 vacations, but those met with such short shrift that they fell out of fashion.

Rule 155 remains as a bulwark of Tax Court practice; the parties, not the judges, do the numbers. I can’t see Judge Courtney D. (“CD”) Jones spending her leisure time booting up the TurboTax for the year at issue and sorting out Joseph William Sherman, Docket No. 22276-19, filed 8/24/23.

I didn’t blog Joseph William (that’s Doc Joseph William of the emergency room) when he appeared in T. C. Memo. 2023-63, filed 5/17/23, a mixture of “goofy regulation” and indocumentado, with little “to detain the tourist”, as that tire man says.

Doc Joseph William tried a Motion for Default and Dismissal, wherein he tried to reargue his case; this was too late for Rule 161 (30 days from opinion) and hadn’t any numbers to comply with Rule 155. IRS did the numbers, to which Doc Joseph William replied with an Answer.

“Therein, Dr. Sherman again disagreed with the Court’s Memorandum Opinion and asked the Court to review its findings. Dr. Sherman did not comply with the provisions of Rule 155.” Order, at pp. 1-2.

Enter decision for IRS.

Note to petitioners: When you have the papers, pound the papers. When you have the numbers, pound the numbers. When you have neither papers nor numbers, go pound sand.