Opinion
27864-21
04-19-2022
ADRIAN L. SANCHEZ & JENAL C. VALDEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
Upon further review of the Petition filed in this case on August 11, 2021, the Court notes that it has not been properly executed, insofar as it has not been signed by petitioners or by a practitioner admitted to practice before this Court, as required by the Tax Court Rules of Practice and Procedure.
However, on April 18, 2022, the parties filed a Proposed Stipulated Decision, resolving the underlying tax liability that is the subject of this proceeding. Insofar as the Court's procedures require a stipulated decision to bear the original signature of the taxpayer, provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, petitioners' intentions to file and prosecute the case in this forum have been adequately verified.
Upon due consideration and for cause, it is
ORDERED that, when the Stipulated Decision is entered in due course, the Petition in this case, filed August 11, 2021, shall be deemed to have been ratified and affirmed by petitioners.