James Robert Serena & Michael Hunter Waybright, Docket No. 13580-21S, filed 10/31/25, are fighting over $15K of Waybright’s NEC allegedly withheld by the nonemployer, which IRS says they can’t verify.

Ch J Patrick J. (“Scholar Pat”) Urda needs none of his scholarship to blow this one off. Turning to the trusty saved boilerplate on the wordprocessor, he unloads the 652 (count ’em, 652) word essay on Tax Court’s Congressionally-limited jurisdiction.

Of course Serena & Waybright fit none thereof, so are relegated to USDC or USCFC, and best of luck with a $15K claim.

As usual, “the record at this juncture suggests that petitioners may have sought the assistance of the Court after having become frustrated with administrative actions by the IRS and any attempts to work with the agency but that the petition here was not based upon or instigated by a specific IRS notice expressly providing petitioners with the right to contest a particular IRS determination in this Court.” Order, at p. 3.

So Serena & Waybright are out $15K, sixty Georges, interest on their money, and lost time.

I can’t help them, or others with similar problems, but I can suggest something to help future frustrated self-representeds and prevent them from wasting money, time, and energy.

Remember, chaps, fully seventy (count ’em, seventy) percent of Tax Court petitioners are self-represented.

Taishoff says, put the boilerplate Tax Court jurisdiction essay on the Tax Court website! Prominently. With a heading like Before You Petition, Read This!

Maybe so might could be the Genius Baristas and 18Fs or whoever else is cobbling together the new, rock ’em-sock ’em, jim-handy Tax Court homepage (coming soon to a URL near you this Monday Nov. 3) might want to do this.

Of course I might be too late, but I never saw a beta of this new, rock ’em-sock ’em, jim-handy whatever.