I ask a lot of questions in this my blog. Proceedings in Tax Court cover so wide a range of human activity that nothing (seemingly) is too remote. I just now saw that Kevin J. Mirch and Marie C. Mirch, T. C. Memo. 2025-128, filed 12/11/25, had answered a question I has asked back in June, 2023.  See my blogpost “Bar Exam?” 6/28/23.

The Mirchs had asked then-Judge Patrick J. (“Scholar Pat”) Urda to stay proceedings in their CDP while Kev, an attorney, got advice from the CA Bar; but the nature of the request was never stated.

Now comes the answer.

“Petitioners requested a stay because of concerns with an ethical issue regarding self-representation. We granted the stay over respondent’s objection.” T. C. Memo. 2025-128, at p. 9.

The opinion itself is the usual mix of Section 469 real estate nonprofessionalism and sloppy bookkeeping by Exam, Appeals, and petitioners.

What is unusual is what Judge Goeke says petitioners did on the trial. “Petitioners spent a substantial amount of time during the trial and in their Posttrial Briefs trying to relitigate not only issues the Court previously decided but also issues respondent has conceded. They misquoted and mischaracterized evidence in the record and made allegations of wrongdoing not supported by evidence.” T. C. Memo. 2025-128, at p. 32.