He Can’t Represent Her

It’s beyond a perennial, more like an invasive species. This is the representative (who would be an ‘Agent” under a State POA, but Form 2848 styles a “representative”) who signs a Form 2 petition.

The boilerplate rebuke is common, and probably resides in the Tax Court form file. But before a copy-and-paste hits the screen, someone should really eyeball the resulting Order one last time.

Here’s Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan in Camille Nini, Docket No. 5936-255 (sic), filed 5/9/25. Camille did sign the petition.

“The petition was also signed by Robert J. Bugdal who appears to be petitioner’s non-attorney representative. The record shows that Robert J. Bugdal is not admitted to practice before the Tax Court. The United States Tax Court, which is separate and independent from the Internal Revenue Service, has certain requirements that must be met before an individual can be recognized as representing a petitioner before the Court. Unlike the IRS, the Court does not recognize powers of attorneys and, thus, petitioner’s non-attorney representative may not represent it in this case.

“The Court has prepared Q&A’s on the subject ‘Representing a Taxpayer Before the U.S. Tax Court’. The Court also encourages practitioners and non-attorneys seeking admission to practice before the Court to consult ‘Guidance for Practitioners’ on the Court’s website at http://www.ustaxcourt.gov/practitioners.html. At this juncture James E. Wilson will not be associated with this case and we encourage petitioner’s representative to review the Court’s admissions requirements.” Order, at p. 1.

Taishoff respectfully suggests that Messrs. Bugdal and Wilson, and any other non-attorney who wants to jump into the Adult Swim on Second Street, NW, check out my blogpost “Coming in November,” 5/6/25. And hit those study resources hard; if you’re expecting an easy trip, you won’t get it.

Come to think of it, maybe so y’all should check out my blog every working day.