Opinion
17714-22
10-31-2022
NAJIBULLAH NAJIB AKRAMI & GULSUM NAJIB AKRAMI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
Pending in the above-docketed matter is petitioners' Motion for Entry of Decision, filed August 8, 2022. By Order dated August 19, 2022, the Court directed petitioners to file a ratification of petition bearing petitioners' original signatures. No ratification of petition has been received.
On September 30, 2022, the parties filed a document designated as a Settlement Stipulation. Upon review of that filing, the Court notes that the document is more akin to a proposed stipulated decision. As the Court's procedures require all stipulated decisions to bear original signatures and the party who files the decision to maintain the paper copy, petitioners' intentions to file and prosecute the case in this forum has been adequately verified. While we would ordinarily recharacterize the Settlement Stipulation as a proposed stipulated decision, the Court notes that the proposed decision document includes a typographical error. Therefore, we will instead enter a decision in accordance with the agreement of the parties as set forth below. Upon due consideration and for cause, it is
ORDERED that petitioner's motion for entry of decision is granted in that the Court will enter a decision as set forth below. It is further
ORDERED that based upon the signatures of petitioners on the parties' Settlement Stipulation, the petition in this case, filed August 2, 2022, is deemed ratified and affirmed by petitioners. To give effect to the basis of settlement agreed upon between the parties as reflected in the Settlement Stipulation, it is further
ORDERED and DECIDED that there is no deficiency in income tax due from, nor overpayment due to, petitioners for the taxable year 2019.