Opinion
9543-22L
10-27-2022
MARCEL C. CHAPPUIS & PATRICIA L. CHAPPUIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 25, 2022, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. However, review shows multiple issues that prevent entry. First, the decision references March 16, 2021, as the date of the underlying notice of determination, whereas such document is dated March 16, 2022. Second, the document is signed by Taylor L. Randolph on behalf of petitioners, but he has never entered a proper appearance in this case. Moreover, even if Taylor L. Randolph were to file an Entry of Appearance, a Ratification of Petition signed by petitioners personally would still be needed before the Court would have jurisdiction in this case. Alternatively, petitioners could sign the Proposed Stipulated Decision personally.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed October 25, 2022, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that the time within which petitioners shall file a Ratification of Petition, bearing both petitioners' original signatures (preferably in blue ink) and ratifying the petition previously filed is hereby extended to November 28, 2022. If no such Ratification of Petition is received by that date, the Court may dismiss this case for lack of jurisdiction. Petitioners should note that the Tax Court, unlike the Internal Revenue Service (IRS), does NOT recognize powers of attorney.