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Famous Tax Quotes - Confusing the Terms “Petitioner” and “Respondent”

2023-05-19

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Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is:

[The taxpayer’s attorney] cites several inapplicable authorities, advances multiple unfounded arguments, and ignores the Court’s limited inquiry in the instant case. First, [the taxpayer’s] objection is nearly unintelligible because it repeatedly confuses the terms “petitioner” and “respondent.”

Gayou v. Commr., T.C. Memo. 2023-61.

From the Tax Court website:

A party who files a petition in response to an IRS notice of deficiency, notice of determination, or notice of certification is called the “petitioner”. The Commissioner of Internal Revenue is referred to as the “respondent” in Tax Court cases.

Tags: Other - Famous Tax Quotes