Attorney-at-Law

THE CODES

In Uncategorized on 12/03/2024 at 16:04

No, not the IRC nor the CFR. These are the “event codes” on the docket sheets, both printable and unprintable, to be found on the Tax Court website. While these are most of them self-explanatory (e.g., “P” for Petition, “A” for Answer, “NOTR” for Notice of Receipt of Petition), today I found one that was puzzling.

I couldn’t get an explanation by telephone, as docket section thought petitions were the ones that employed it, but neither they nor petitioner’s counsel was available by telephone. The event code is MIND, and the case is Cylie G. Fields, Docket No. 5819-23S, filed 12/3/24.

Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan’s order is brief: “the caption of this case is amended by adding the letter ‘S’ to the docket number.” Order, at p. 1. Unusual, as there’s no motion to restore the case to small-claimer treatment, nor any statement that the preceding regular case treatment was inadvertent.

A docket check shows that in April a year ago, when the petition was filed as a small-claimer, the initial docket number was amended the next day to omit the letter “S” suffix, with no explanation save the event code “MIND.” “My bad”?

Edited to add, 12/5/24: I heard today from Sarah Silfies Finken, Esq., Administrative and Case Services Counsel at Tax Court, that “MIN” signifies minute entry, that is, docket clerk’s entry to correct or supplement a docket entry, which may or may not be directed by an order of the Court; the letter “D” means Docket. While in this case there may have been an error, Ms. Finken notes that, with the huge volume of cases, there are very few errors. And indeed, in my experience, this is so.

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