CH J Patrick J. (“Scholar Pat”) Urda gives me a hint to reconsider my so far unsuccessful campaign to permit omnibus motions in Tax Court.

Kevin R. Reilly & Paige N. Hopkins, Docket No. 2122-25P, filed 10/3/25, really pushed the envelope. “Petitioners filed the Petition in the above-docketed matter, indicating therein that they seek review of a Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the Department of State and a Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 (or Failure of IRS to Make Determination Within 6 Months After Election or Request for Relief).” Order, at p. 1. (Footnote omitted). 

True, this is a petition, not a motion, but the principle is the same: while it is expedient to deal with related matters, principally discovery or evidentiary, in a single-shot order, there’s a vanishing point where questions of law and fact diverge so widely that no size can possibly fit all.

CJ Scholar Pat need not go so far, as neither Kev nor Paige can produce anything showing either that a NOD issued or six months had passed pre-petition since election or request on the innocent spousery side. Of course, Ken & Paige are pro ses, so I’m not surprised if they don’t know what they need to put in to save their Section 6015 claim, even though Ch J Scholar Pat gave them a second chance to do so.

That said, this sort of thing (Paige is the one with the alleged debt, Order, at p. 1, footnote 2) would necessitate bifurcation even if Kev & Paige had the innocent spousery receipts. So the single-shot really misses the mark in such a case.