In a memorandum decision in the recent ADOR v. Smith case, the Arizona Court of Appeals upheld a default judgment against a pro se litigant. The judgment stemmed from an administrative hearing officer's ruling that upheld ADOR's assessment of income tax, penalties, and interest that Ms. Smith failed to appeal. Finding that Ms. Smith failed to comply with the court's procedural rules, the court noted that it "hold[s] self-represented litigants to the same standard as attorneys and expect[s] them to make 'a bona fide and reasonably intelligent effort to comply with the [procedural] rules.'" To track developments relating to proposed Arizona tax legislation, please visit this page on my website. | 
