Opinion
30000-21S
03-16-2022
Brian Wade Cunningham Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 27, 2021, the Court received in the above-docketed case a document from and signed by Elizabeth M. Cunningham, indicating an intention to ratify the petition filed herein on September 10, 2021. That document was lodged as a Ratification of Petition by Elizabeth M. Cunningham. Although the initial petition had been captioned only in the name of and executed only by Brian Wade Cunningham, the underlying notice of deficiency had been issued jointly to both individuals.
Upon due consideration, and for cause appearing of record, it is
ORDERED that the Clerk of the Court is directed to file the just-referenced Ratification of Petition by Elizabeth M. Cunningham as of the date this Order is served. It is further
ORDERED that the caption of this case is changed to read "Brian Wade Cunningham & Elizabeth M. Cunningham, Petitioners v. Commissioner of Internal Revenue, Respondent".