Opinion
18833-22S
03-29-2023
KEVIN DOUGLAS BOYHAN & KAREN GOFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On March 28, 2023, 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 2021 issued solely to petitioner Kevin Douglas Boyhan. Thereafter, and somewhat inexplicably, respondent filed an Answer silent as to the apparent jurisdictional discrepancy involving Karen Goff, 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 April 19, 2023, respondent shall file either: (1) An appropriate jurisdictional motion as to Karen Goff; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Karen Goff and attaching thereto a copy of any supporting documentation.