I’ve often criticized the vagaries of DAWSON’s creek, from. the months-long shutdown that preceded its opening to its teething pains and later glitches. But Sergio Martinez and Arely Tolentino, et al., Docket No. 18467-24, filed 2/17/26, though stymied by DAWSON, reveal the lacking human element.

Ch J Patrick J. (“Scholar pat”) Urda tells the story. Note the dates.

“On August 28, 2024, petitioners filed in paper form an imperfect Petition to commence the case at Docket No. 13995-24. By Order issued August 28, 2024, the Court directed petitioners to file a proper amended petition. After having received no response from petitioners, on November 19, 2024, the Court entered at Docket No. 13995-24 an Order of Dismissal for Lack of Jurisdiction and that case was closed. The Order of Dismissal stated that, if petitioners filed an amended petition within 30 days, the Court would consider vacating the dismissal and reinstating the case.

“On November 25, 2024, without having eAccess to their above-referenced case, it appears petitioner Sergio Martinez attempted to electronically file the amended petition. That action resulted in a separate Petition being filed to commence the case at Docket No. 18467-24.” Order, at p. 1.

Taishoff says notwithstanding Sergio’s electronic miscue, a docket search shows the amended petition filed 11/25/24 as stated.

IRS moves to toss that stealth amended petition 1/7/26. 

The same docket search shows that a year went by with a SPTO, a change of address for one of IRS’ counsel, an EoA (no counsel stated for Sergio; must be IRS counsel), and a Notice of Trial for venue Sergio requested.

IRS apparently assigned three (count ’em, three) attorneys to this case.

No crosschecking. No followup.

Ch J Scholar Pat has to straighten this out.

No comment.