Eighty percent of Tax Court petitioners are self-represented.

When I consider the wasted time and clerical and judicial brainpower caused by good-faith Tax Court  pro ses, to say nothing of the (possibly) greater amount squandered on bad-faith gameplayers and dodgers, I shake my head. Whatever the expense of an Office for the Self-Represented, such as many courts, State and Federal, already have, I cannot understand why US Tax Court hasn’t the same.

Two (count ’em, two) cases in point.

Scott M. Balotin and Ellen M. Balotin, Docket No. 9174-25P, filed 2/4/26, is only tangentially about a passport grab, because IRS reversed the certification and told DoS, so Judge Goeke moots that out. The penalty abatement case is mooted out because a stiped decision in another case says the don’t owe any penalties for that period. Interest abatement must await trial because petitioners claim they filed Form 843, but IRS says they haven’t got it. Nevertheless, IRS agreed to the stiped decision, so let IRS show why the proffered Form 843 shouldn’t be considered as an administrative request for abatement of interest. Finally, Ellen’s innocent spousery claim. “Petitioners have not established that Ms. Balotin filed or made an administrative request for innocent spouse relief with the IRS. Also, they have not produced a Notice of Final Determination relating to Ms. Balotin’s request for innocent spouse relief. Nor have they asserted that they filed or made an administrative request or received a Notice of Final Determination. Accordingly, we do not have jurisdiction to determine whether Ms. Balotin is entitled to innocent spouse relief….” Order, at p. 2.

Couldn’t a clerk sort this out?

Next, Andre Pierre Harris, Docket No. 15845-25, filed 2/4/26, is apparently the sort of thing STJs see every day. There’s a petition with no attachments, which IRS moves to dismiss, to which there is a response that agrees, from someone claiming authority but not producing proof. I’ll let ex-Ch STJ Lewis (“My Kind of Name”) Carluzzo explain. “The Court notes that the pattern of allegations in the petition in this case, more or less, is identical to the pattern of allegations made in petitions in hundreds of other cases filed in this Court that involved taxpayer/petitioners who were apparently ill-advised. We accept, if only in the absence of anything that establishes otherwise, B’s authority to have appeared at the hearing on petitioner’s behalf but otherwise reject many of the answers that she gave in response to questions by the Court.” Order, at p. 1. (Name omitted).

“Hundreds of ill-advised taxpayer/petitioners” clogging the system to the detriment of those with meritorious claims.