To begin with, I do not know the facts and circumstances that led to the trusty attorney for Linda S. Bienstock, Docket No. 11167-26S, filed 11/6/26, being admonished by Ch J Patrick J. (“Scholar Pat”) Urda that said trusty attorney “will not be associated with this case until an entry of appearance is filed in accordance with Tax Court Rules of Practice and Procedure.” Order, at p. 1.

A brief DAWSON search reveals said trusty attorney has been admitted to the Tax Court Bar for fifty (count ’em, fifty) years. A search of Our Fair State’s Office of Court Administration website shows said trusty attorney to be a member of a well-known firm located on a Minor Outlying Island off the Coast of North America adjacent to the Minor Outlying Island whereon I am writing these lines.

I cannot think the nonfiling of the Form 7 is thus a rookie error. More likely it is a case of “beat the clock,” the last-minute efiling as the Section 6213(a) 90-day window expired. As the petition was filed 11/2/26, I would expect that said trusty attorney, having beaten the clock, thought he could take a breath and prepare and file the proper documentation later this week, having put out whatever other fires he had burning on Monday.

Tax Court procedure relies so heavily upon public orders that a phonecall or an email from one of Chief Clerk Jeane’s minions to said trusty attorney, along the lines of “hey, guy, file an EoA, OK?” is out of the question.

Taishoff asks whether scarce judicial resources cannot better be employed.