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Hanson v. Comm'r of Internal Revenue

United States Tax Court
May 2, 2022
No. 9091-22S (U.S.T.C. May. 2, 2022)

Opinion

9091-22S

05-02-2022

CATHERINE A. HANSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Maurice B. Foley Chief Judge

On April 4, 2022, the petition commencing this case was electronically filed. When a petition is electronically filed with the Court, the combination of the username and password of the individual efiling the petition serves as the signature of that individual. See the DAWSON User Guides on the Court's website, www.ustaxcourt.gov. The petition in this case was electronically filed using an email address belonging to Joan K. Aronson, and thus the petition is treated as having been signed by that individual. The petition lists Ms. Aronson's name and appears that she is purportedly representing petitioner in this case. However review shows that Joan K. Aronson is not admitted to practice before the Court pursuant to Rule 200, Tax Court Rules of Practice and Procedure. It is well settled that, unless the petition is filed by the taxpayer or an individual who is lawfully authorized to act on the taxpayer's behalf, we are without jurisdiction. See Fehrs v. Commissioner, 65 T.C. 346, 348-349 (1975). At this juncture, Ms. Aronson will not be associated with this case and the email address used to electronically file the petition will be disabled from the record in this case. If petitioner wishes to continue to prosecute this case, petitioner must file a proper ratification of petition, ratifying and affirming the petition that was filed on her behalf.

Furthermore, as Joan K. Aronson is not admitted to practice before this Court and she cannot represent petitioner in this case. The Court has prepared Q&As on the subject "Representing a Taxpayer Before the U.S. Tax Court. A copy of these Q&As are attached to this Order. The Court encourages practitioners and non-attorneys seeking admission to practice before the Court to consult "Guidance for Practitioners" on the Court's website at www.ustaxcourt.gov/practitioners.html. Petitioner is advised that they may represent themselves or seek representation by an individual who is admitted to practice before this Court. An individual admitted to practice before the Court will have an assigned Tax Court Bar number.

Upon due consideration and for cause, it is ORDERED that the Clerk of the Court shall make petitioner's service preference as paper in the record of this case. It is further ORDERED that, on or before June 28, 2022, petitioner shall file in paper form a proper ratification of petition bearing her original signature ("wet ink" signatures, not a photocopy). Petitioner should note that the ratification of petition may not be filed electronically. Failure to comply with this Order may result in the dismissal of this case for lack of jurisdiction. It is further

ORDERED that the Clerk of the Court is directed to attach to this Order a form that petitioner may use to comply with this Order. It is further

ORDERED that the Clerk of the Court is directed to attach to the copy of this Order the Court's Q&As on the subject "Representing a Taxpayer Before the U.S. Tax Court". It is further

ORDERED that Ms. Aronson may file a entry of appearance, if she wishes to enter her appearance in this case upon meeting the Court's admissions requirements. It is further

ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on Joan K. Aronson at the address listed for her on page 2 of the petition.


Summaries of

Hanson v. Comm'r of Internal Revenue

United States Tax Court
May 2, 2022
No. 9091-22S (U.S.T.C. May. 2, 2022)
Case details for

Hanson v. Comm'r of Internal Revenue

Case Details

Full title:CATHERINE A. HANSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: May 2, 2022

Citations

No. 9091-22S (U.S.T.C. May. 2, 2022)