Opinion
13134-21
03-07-2022
Richard Crain & Christine Crain Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
By Order served July 14, 2021, the Court directed petitioner Richard Crain to file a ratification of petition. To date, Mr. Crain has not complied with that Order.
However, on February 28, 2022, 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 a stipulated decision to bear the original signature of the taxpayer, provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, Mr. Crain's 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 April 16, 2021, shall be deemed to have been ratified and affirmed by petitioner Richard Crain.