It’s one thing to receive The Phone Call, whether the icy, hissing version or the profanity-laced scream, in either case from the client whose case you’ve blown, or at least concluded otherwise than to their utterly ecstatic satisfaction. It’s another to have to make the outgoing variety oneself, to broker or insurer or, preferably, to both, requesting a notice of claim form.

If you have never been there, bless whatever gods may be, and pray said gods ever hold you in the palms of whatever limbs they have.

But here is a warning to us all.

Joel A. Dilillo, Docket No. 14110-23, filed 11/27/23, has his petition tossed. It’s the usual Hallmark Rsch. Collective SNOD petition filed too late. Joel is in 1 Cir, so Culp is off the menu.

Here’s Ch J Kathleen (“T.B.S. = The Big Shillelagh”) Kerrigan.

“…petitioner appeared to take the position that the petition should be considered timely based on timely mailing to the Internal Revenue Service (IRS), as follows: ‘The Petition was filed timely on August 4, 2023. As a result of an administrative error, the envelope with the Petition was mailed to the Internal Revenue Service. My files include labels that have the IRS mailing address and also the U.S. Tax Court address. Obviously, I took the wrong label that had the IRS address rather than the U. S. Tax Court label.’ Attached to the objection was a bank statement reflecting a charge paid to the USPS on August 5, 2023, for an amount corresponding to the postage on the envelope addressed to the IRS (a charge of a different amount paid to the USPS on August 4, 2023, was also shown).” Order, at p. 2.

IRS of course forwarded the petition to The Glasshouse on Second Street, N.W., a couple weeks later (hi, Judge Holmes), but after the 90-day cutoff.

Clearly, the petitioner himself never wrote that. What client keeps her/his own files with bunches of IRS and USTC address labels?

Ch J TBS Kerrigan is sympathetic, and so am I.