The best thing I can write about the DTA’s production this week is that I get to use both of the words TiNY has created in the same sentence. This week there is one Tribunal decision and one ALJ determination, and they are a timy and a costy, respectively. And, as Forrest Gump once mused, that’s all I have to say about that.
“It is a truth universally acknowledged, that a lawyer in possession of extra time, must be in want of a blog.”
And with that paraphrase, I welcome you, constant reader, to the “Pride and Prejudice” edition of TiNY.
I expressed a lack of sympathy for the plight of the petitioners involved in the cases I summarized last week. As I started reading through this week’s DTA production, my thinking was much more “on brand.” I am, after all, on “Team Taxpayer,” and I tend to revert to that norm absent some really annoying taxpayer antics. Anyway, I was easing back into my pro-taxpayer comfort zone when I read the last determination summarized below, and BAM!, I was blown right back into wondering just what-the-heck some Petitioners are thinking. And, not for the first time, I wondered whether the $500 frivolous pleading penalty is really a big enough deterrent.