Opinion
13583-23
09-20-2024
CLARK B. BISHOP & TRACEY A. BISHOP, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On September 19, 2024, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. Prior to entry of a stipulated decision, however, it is advisable to ensure that the record herein is complete insofar as concerns the documentation (1) relevant to establish the Court's jurisdiction over all parties and taxable periods and/or (2) referenced in the decision. Here, the petition commencing the case attached a notice of deficiency for the taxable year 2017 issued solely to petitioner Clark B. Bishop. Thereafter, and somewhat inexplicably, respondent filed an Answer silent as to the apparent jurisdictional discrepancy involving Tracey A. Bishop, a problem now compounded by the even more inscrutable submission of a Proposed Stipulated Decision.
Accordingly, upon due consideration, it is
ORDERED that, on or before October 4, 2024, respondent shall file either: (1) An appropriate jurisdictional motion as to Tracey A. Bishop; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Tracey A. Bishop and attaching thereto a copy of any supporting documentation.