Yes, I know, in United States Tax Court a matter of seven years is but the twinkling of an eye. However, I do want to claim modest credit for blogging away back in April, 2018, what Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan unloads on Hannah K. Heart, Docket No.  13242-24, filed 5/15/25.

Hannah tries an oldie-but-not-goodie, filing a petition but not specifying year(s) at issue, nor attaching SND nor NOD. IRS moves to dismiss for want of jurisdiction, claiming they never issued either to Hannah from 2014 (a year when she raises a Form 843 seeking abatement of a penalty or addition to tax) to the present.

OK, possibly just a misapprehension of the law. We’ve seen dozens.

Except.

“… petitioner previously filed a case in Docket No. 10216-18 seeking review of notices of deficiency and notices of determination for tax years 2000 through 2017 that was dismissed for lack of jurisdiction on the ground that no notice of deficiency or notice of determination was issued to petitioner that would permit her to invoke this Court’s jurisdiction.” Order, at p. 2.

Reckoning Hannah should know better, Ch J TBS shows Hannah the Section 6673 yellow card.

See my blogpost “I’m Beginning to See the Light,” 4/9/18.