I’m sure neither party to Estate of Randy M. Harrigan, Deceased, Kyle Harrigan, Executor, Docket No. 7245-25S, filed 6/3/26, is so ill-bred as to add the adjective that Alfonso Bedoya never said in the most-misquoted sentence from that 1948 classic. And Ch J Patrick J. (“Scholar Pat”) Urda would never think of saying such a thing.

But he does seek to toss Kyle’s petition, because although Kyle was duly appointed ex’r of Randy’s estate, he was disappointed less than a year later. Hence when Kyle petitioned after he was disappointed, there was no one with authority to petition.

So Ch J Scholar Pat tosses the Proposed Stipulated Decision that Kyle and IRS hammered out. And he orders the parties to show cause why the whole case shouldn’t be tossed for want of jurisdiction.

OK, so far no biggie; there are dozens of cases like this.

Except.

Ch J Scholar Pat offers the parties an out.

“The Court notes that, although it appears that we lack jurisdiction of this case, the parties are free to enter into an administrative resolution in accordance with the terms set forth in the above-referenced Proposed Stipulated Decision.” Order, at p. 1.

Taishoff says that’s well and good, but if disappointed Kyle has no authority to represent the estate in Tax Court, what authority has he to enter into any enforceable resolution on behalf of the estate with anyone anywhere?