The order in Lucille Pilibos, Docket No.19245-24S, filed 7/30/25, gives only the scantiest recitation of facts, as is usual. Nor does STJ Diana L. (“Sidewalks of New York”) Leyden provide any commentary in granting the motion to appoint petitioner’s daughter as a Rule 60(d) next friend.

Daughter says Luncile is 104 years old and lacks mental capacity to handle her taxes. Daughter holds durable power of attorney for Lucile.

Routine, “garden variety” situation, right?

Except.

Both Lucile and daughter are pro se, and neither is movant. Daughter furnishes a declaration in support of the motion, but movant is stated to be “Respondent.”

Is IRS counsel furnishing legal advice to daughter and drafting her motion papers? Is this the new normal?