I’ve often questioned why Tax Court Rules prohibit omnibus motions and multiplex EoAs. Judge Courtney D. (“CD”) Jones provides an answer in Staven A. Stover & Cynthia Stover, Docket No. 6836-24L, filed 6/11/26. Staven & Cynthia fire off a salvo under the heading of “Answer”: a Motion to Remand, a Motion to Supplement the Admin Record, a Reply to Respondent’s Answer, and a Cover Letter to Appeals.

There’s “omnibus” and then there’s “buckshot.”

Judge CD Jones is not having any of it.

“The Court has repeatedly advised petitioners that compound filings are improper; they do not conform to the Court’s Rules (see Docs. 30, 45). Petitioners must file motions directly with the Court in the manner prescribed by the Court’s Rules, which are available on the Court’s website. If petitioners wish to re-file the documents mentioned above, then petitioners must file each document separately in accordance with the Court’s Rules. Accordingly, the Court will strike petitioners’ Answer (Doc. 46).” Order, at p. 1.

Deer-in-the-headlights pro ses should check out the “Guidance for Petitioners” link on the Tax Court website, and e-mail the DAWSON Genius Baristas support crew (although Taishoff says don’t expect much).

Finally, Staven & Cynthia might try a LITC; that’s their best bet. 

Another compound that needs breaking is the term “Power of Attorney.” Judge James S (“Big Jim”) Halpern, confronted in Edward H. Fitzelle & Jane E. Croes,  Docket No. 13476-25L, filed 6/11/26 with Form 2848, designates an individual as a Power of Attorney; Form 2848 does not. Form 2848 designates a “Representative.” Form 2848 is a Power of Attorney, hence either a piece of paper or a concatenation of electrons. Forms of power of attorney other than Form 2848 designate an “Agent” or “Attorney-in-Fact.” Sometimes the last named is abbreviated as “AiF”. But all such forms are just that: forms. Why not just call a Representative a Rep, to distinguish that person from a Partnership Representative, or P-Rep?