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Akrami v. Comm'r of Internal Revenue

United States Tax Court
Aug 22, 2022
No. 17714-22 (U.S.T.C. Aug. 22, 2022)

Opinion

17714-22

08-22-2022

NAJIBULLAH NAJIB AKRAMI & GULSUM NAJIB AKRAMI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan, Chief Judge

On August 8, 2022, the Court filed a Letter by Petitioner. Therein, petitioner Najibullah Najib Akrami advises that petitioners have reached an agreement with the Internal Revenue Service in this case and have received an IRS Notice CP3581 "No Change Letter" dated August 1, 2022. A copy of the so-called "No Change Letter", indicating that the examination of petitioners' 2019 taxable year has been closed with no changes, is attached to petitioner's Letter.

In a deficiency case where this Court has jurisdiction, the Court is generally required to enter a decision specifying the amount of the deficiency, if any, for the taxable year at issue. See I.R.C. § 7459(d); Estate of Ming v. Commissioner, 62 T.C. 519 (1974). Therefore, even if the parties have reached a settlement, as it appears may have occurred in this case, the Court must enter a decision. Accordingly, we will recharacterize the Letter and direct the parties as set forth below.

Upon due consideration of the foregoing, it is

ORDERED that the above-referenced Letter is recharacterized as petitioners' Motion for Entry of Decision. It is further

ORDERED that, on or before October 21, 2022, respondent shall file a response to the Motion for Entry of Decision, or the parties shall file a proposed stipulated decision.


Summaries of

Akrami v. Comm'r of Internal Revenue

United States Tax Court
Aug 22, 2022
No. 17714-22 (U.S.T.C. Aug. 22, 2022)
Case details for

Akrami v. Comm'r of Internal Revenue

Case Details

Full title:NAJIBULLAH NAJIB AKRAMI & GULSUM NAJIB AKRAMI, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Aug 22, 2022

Citations

No. 17714-22 (U.S.T.C. Aug. 22, 2022)