No, not another incursion by the Supremes into pore l’il ol’ Tax Court’s minuscule jurisdiction. This is Judge Courtney D. (“CD”) Jones exhibiting restraint and invoking the “yellow card before the Section 6673 chop” for self-represented protester/defiers.

Judge CD Jones has Jeffrey Dominic Grinaldi, Docket No. 1288-23, filed 2/27/24, making his second appearance at The Glasshouse in the City-NonState. He stiped out at the last one, so no published order, much less opinion. I will again point out, as have more vehemently my colleague Mr. Paul Streckfus of EO Tax Journal and Prof. Leandra Lederman at U of IN, that these stipulated decisions should be made available online. See my blogpost “Made Available for Public Inspection,” 11/9/18.

Casting aside the Tax Court prime directive, Jeff and IRS have a multi-motion joust, resulting from “both respondent and petitioner’s declinations to schedule a Branerton conference.” Order, at p. 2.

Judge CD Jones blows off Jeff’s motions, and sets IRS’ request for a Rule 103 protective order down for a hearing. I’m sure it’ll be quite a hearing.

Howbeit, Jeff does get a bye on the Section 6673 frivolity chop, exemplifying the caption or title first set forth at the head hereof, as my “Yes, I’ll have another Grey Goose Gibson with a little less Dolin’s, please” colleagues have just said.

“Mr. Giraldi has previously been a litigant before this Court. See Docket No. 15190-19. Respondent states that in that case, Mr. Giraldi made similar types of arguments to those he advances in the instant case, but that respondent leniently did not move to have the Court impose a penalty pursuant to section 6673. Upon review of the record at Docket No. 15190-19, that case was resolved by stipulated decision, and it does not appear that the Court warned Mr. Giraldi of the possibility of requiring him to pay a penalty to the United States of up to $25,000. Accordingly, we will not impose a penalty under section 6673 at this juncture, and we will deny respondent’s Motion to Impose a Penalty without prejudice to renew.” Order, at p. 4.

However, lest Jeff get too elated, “we admonish Mr. Giraldi that if he raises frivolous arguments before the Court, respondent could file another motion to impose a penalty, or the Court, on its own motion, could impose a penalty under section 6673.” Order, at p. 4.

So play nice, chaps, and show up in all respects ready to try the case at calendar call.