Attorney-at-Law

FOR THE RECORD

In Uncategorized on 10/30/2025 at 16:46

I’ll mention Carol Rae Foulds, T.  C. Memo. 2025-111, filed 10/30/25, only to show I’m still here. I haven’t fallen into the stockpot where my celebrated Bolognese sauce is doing its three (count ’em, three) hour simmer.

The case is another NITL summary J barrelshoot on a pro se who hadn’t filed for seven (count ’em, seven) years when IRS gave her a couple SFRs (hi, Judge Holmes) for two of the bunch. Dr. Foulds never petitioned liability. There follows the usual argy-bargy about presumptive mailing, the defective PS3877 paperwork followed by IRS showing they don’t need no stinkin’ presumption of mailing, and Dr. Foulds folding the summary J motion, as Ch J Patrick J. (“Scholar Pat”) Urda trots around the bases.

It’s a miserable rainy night on this Minor Outlying Island off the Coast of North America. So while waiting breathlessly for the rollout of the new Tax Court homepage, this is what I do between stirrings.

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