Seems an old-time protester/defier move is making a comeback. Joel S. Bliss & Valerie S. Bliss, Docket No. 10609-24, filed 9/30/24, are a couple weeks (hi, Judge Holmes) late with their petition from a SNOD.

When IRS moves to toss, Joel & Valerie respond with “the notice of deficiency is invalid because it violates I.R.C. section 6065, which states in relevant part: ‘Except as otherwise provided by the Secretary, any return, declaration, statement, or other document required to be made under any provision of the internal revenue laws or regulations shall contain or be verified by a written declaration that it is made under the penalties of perjury.'” Order, at pp. 2-3.

Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan rejects.

“Petitioners, however, are mistaken. Section 6065 imposes requirements on documents filed by taxpayers and does not apply to the Commissioner. See Davis v. Commissioner, 115 T.C. 35, 42 (2000)*.” Order, at p. 3.

As the old song says, “for you, not for me.”

* https://casetext.com/case/davis-v-commr-of-internal-revenue-4