Two (count ’em, two) entries for the scrapbook today, one a recurring tale and one where a word of instruction is better than a slammed door.

I’m sure all my readers join me in wishing John R. Dee, Docket No. 12649-16 W, filed 6/12/26, a speedy return to good health. John was here two (count ’em, two) years ago; see my blogpost “Watching Fewer Sunsets in Ogden,” 8/14/24. Now John is protesting an IRS status report, apparently filed while John was sick. STJ Diana L. (“Sidewalks of New York”) Leyden recharacterizes John’s filings and tells IRS to reply to John’s motion to supplement the administrative record. Taishoff says it is unbelievable that ten (count ’em, ten) years after the petition was filed, there should be any question about what comprises the administrative record. Jarndyce v. Jarndyce has nothing on these guys.

Robert Grafton, Docket No. 18878-24, filed 6/12/26, thinks he prevailed when IRS folded pre-trial, so he refuses to sign a stiped decision. He claims the stip as drafted lets IRS off the hook for Section 7430 admins and legals and wants discovery. Ch J Patrick J. (“Scholar Pat”) Urda blows that off. How he does it is what I question. 

“As stated in respondent’s response to petitioner’s Motion, respondent has conceded the determinations made in the notice of deficiency on which this case is based. It thus appears that petitioner’s discovery request would pertain only to litigation costs and to potential actions brought outside of this Court, and would not be ‘relevant to the subject matter involved in the pending case,’ i.e., to the determinations made in the notice of deficiency.” Order, at pp. 1-2. (Citing Rule 70(b)(1)).

OK, but since Robert is pro se, how about a hint that if he wants Section 7430 relief, maybe so might could be he should check out the statute and Rule 231(a)(2)(C)?