Opinion
1110-21S
12-08-2021
Jason S. Bivins & Crystal D. Bivins Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 2, 2021, 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 Crystal D. Bivins. Thereafter, and somewhat inexplicably, respondent filed an Answer silent as to the apparent jurisdictional discrepancy involving Jason S. Bivins, 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 December 30, 2021, respondent shall file either: (1) An appropriate jurisdictional motion as to Jason S. Bivins; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Jason S. Bivins and attaching thereto a copy of any supporting documentation.