Lucas Calhoun, Docket No. 4554-25L, filed 4/17/26, should have been at least considered for a referral to a LITC by Appeals. When Lucas claimed he was disabled and would need help either from his father or his son, sending a couple 2848s (hi, Judge Holmes) really doesn’t answer the problem.
Of course, the IRM contains no such instruction; IRM 8.6.1.5.3.2 (09-25-2019) places the burden on the taxpayer to request representation and to select and qualify the representative. So I’m not saying the SO did anything wrong; he followed the book, and so did STJ Diana L. (“Sidewalks of New York”) Leyden in affirming the SO sustentation of the NITL.
But when a petitioner claims “I Lucas Calhoun was in a car accident in 2018. I was a passenger in a Honda Accord that struck another vehicle head on at 50 mph. We have had a supervisor from the IRS tell us I am not collectible. Also I have a voicemail from Biran at the IRS stating that he spoke to his supervisor and we would not be held liable. To not worry. That was on 6/14/24. Please do not levy the property my dad has my son & I staying at. Please send forms for forgiveness”, Order, at p. 2, maybe so might could be that a nonlawyer nonpractitioner might not be enough.
No one shows up for Lucas, so STJ Di gives IRS summary J.
Maybe so might could be referral to a LITC could save the day. But the SO shouldn’t have to judge this without some cover from high command. Maybe a revision to the IRM? Gives no rights to taxpayers greater than they would otherwise have.
Taishoff Law 
I really hope that the Tax Court actually reads your blog and considers your opinions. Your insights are incredibly thoughtful, and this is no exception – there sometimes just seems to be such a gulf between where most ordinary people are and how the TC behaves, where it’s just too caught up in itself to see what’s really going on and address it like you’d hope human beings of good heart and character ought to.
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Mr Briggs, thank you for your kind words. I understand some people associated with Tax Court have read this my blog. However, the change I propose in this blogpost must come from Treasury to IRS.
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