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Cummings v. Comm'r of Internal Revenue

United States Tax Court
Nov 8, 2022
No. 8434-21 (U.S.T.C. Nov. 8, 2022)

Opinion

8434-21

11-08-2022

MICHAEL J. CUMMINGS & CONNIE A. CUMMINGS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

By Order served May 26, 2021, the Court directed petitioners to file a ratification of petition. To date, no such ratification has been filed.

However, on March 10, 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, the intentions of petitioners 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 10, 2021, shall be deemed to have been ratified and affirmed by petitioners.


Summaries of

Cummings v. Comm'r of Internal Revenue

United States Tax Court
Nov 8, 2022
No. 8434-21 (U.S.T.C. Nov. 8, 2022)
Case details for

Cummings v. Comm'r of Internal Revenue

Case Details

Full title:MICHAEL J. CUMMINGS & CONNIE A. CUMMINGS, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Nov 8, 2022

Citations

No. 8434-21 (U.S.T.C. Nov. 8, 2022)