Opinion
6548-20S
12-16-2021
Mitchell L. Daniels & Betty E. Daniels Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 15, 2021, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision purporting to resolve this litigation. Prior to entry of a stipulated decision, however, it is advisable to ensure that the record herein is complete insofar as concerns the documentation (1) relevant to establish the Court's jurisdiction over all parties and taxable periods and/or (2) referenced in the decision. Here, the petition commencing the case attached a notice of deficiency for the taxable year 2017 issued solely to petitioner Mitchell L. Daniels. Thereafter, and somewhat inexplicably, respondent filed an Answer silent as to the apparent jurisdictional discrepancy involving Betty E. Daniels,, a problem now compounded by the even more inscrutable submission of a Proposed Stipulated Decision.
Accordingly, upon due consideration, it is
ORDERED that, on or before January 5, 2022, respondent shall file either: (1) An appropriate jurisdictional motion as to Betty E. Daniels, ; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Betty E. Daniels, and attaching thereto a copy of any supporting documentation.