Opinion
15314-20
10-06-2021
Jodi Caruso-Reiter & Kenneth Reiter Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 28, 2020, an imperfect petition was filed to commence this case. Among other things, the petition was not properly executed in that it did not bear the original signatures of petitioners or of a practitioner admitted to practice before this Court, as required by the Tax Court Rules of Practice and Procedure. Accordingly, by Order served March 16, 2021, the Court directed petitioners to file a Ratification of Petition. To date, petitioners have not complied with the foregoing Order.
On October 1, 2021, the parties filed a proposed stipulated decision resolving the underlying tax liability that is the subject of this proceeding. As the Court's procedures require all stipulated decisions to bear original signatures and the party who files the decision to maintain the paper copy, 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 December 28, 2020, shall be deemed to have been ratified and affirmed by petitioners.
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