Opinion
7734-21
10-15-2021
Daniel Ciluffo & Krystal Ciluffo Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
By Order served May 20, 2021, the Court directed petitioners to file a Ratification of Petition. To date, petitioners have not complied with the foregoing Order.
On October 13, 2021, the parties filed a Proposed Stipulated Decision resolving the underlying tax liability that is the subject of this proceeding. Insofar as the Court's procedures require all stipulated decisions to bear original signatures of the taxpayers, provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, 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 March 1, 2021, shall be deemed to have been ratified and affirmed by petitioners.