Opinion
6901-24S
05-24-2024
VYACHESLAV SENCHENKO & LYUDMILA SENCHENKO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 2, 2024, 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 Robert@YosephCPA.com. The record also shows that petitioners are receiving assistance from Robert D. Yoseph as their non-attorney representative and the email address appears to belong to him. The Tax Court, unlike the Internal Revenue Service, does not recognize powers of attorney. See Rules 24(a), 200; see also Ruggere v. Commissioner, 78 T.C. 979, 989 (1982). At this juncture and upon review of the entire record, the email address Robert@YosephCPA.com used to electronically file the petition will be disabled from the record in this case.
The petition bore actual signatures for petitioners. Insofar as the Court's procedures require all petitions to bear signatures of the taxpayers provided at minimum to the filing party signature and so maintained by the filing party, petitioners' intention to file and prosecute this case in this forum has been adequately verified.
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 atwww.ustaxcourt.gov/practitioners.html. Petitioners are 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.
ORDERED that the Clerk of the Court shall change petitioners' service preference from "electronic" to "paper." It is further
ORDERED that the Clerk of the Court is directed to attach to the copy of the Order Court's Q&As on the subject "Representing a Taxpayer Before the U.S. Tax. Court." It is further
ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on Robert D. Yoseph at the address which is listed for him on page 2 in the petition.
The Court encourages all litigants to register for DAWSON (Docket Access Within a Secure Online Network),the U.S. Tax Court's electronic filing and case management system. By registering, litigants may electronically file and view documents in their Tax Court case. If you currently file in paper or receive paper service from the Court, petitioners and not power of attorneys must register for DAWSON by sending an email request to dawson.support@ustaxcourt.gov.