Opinion
2103-24S
05-06-2024
MATTHEW R. MAJOR & LISA A. MAJOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 7, 2024, a petition was filed commencing the above-docketed case. That petition, however, was not properly executed in that it did not bear the original signature of petitioner Lisa A. Major or of a representative with proper authorization and capacity pursuant to the Tax Court Rules of Practice and Procedure. Rather, only petitioner Matthew R. Major had signed the petition. Therefore, in order for this Court to acquire jurisdiction to consider this case as to Lisa A. Major, it is necessary to obtain a Ratification of Petition bearing Lisa A. Major's original signature and ratifying the petition previously filed.
By Order dated February 12, 2024, the Court directed petitioner Lisa A. Major to so ratify the petition. A form for that purpose was provided for petitioner's use. To date, nothing has been received from petitioner, and it has come to the Court's attention that the Order in contained in one sentence an erroneous reference to Carlos Ramirez, rather than Lisa A. Major, potentially creating confusion.
Accordingly, upon due consideration and to provide petitioners with a final opportunity to avoid dismissal of this case in part as to Lisa A. Major for lack of ratification, it is
ORDERED that the time within which petitioner Lisa A. Major shall file a Ratification of Petition, bearing Lisa A. Major's original signature (preferably in blue ink) and ratifying the petition previously filed, is hereby extended to May 28, 2024. If no such Ratification of Petition is received by that date, the Court may dismiss this case in part as to Lisa A. Major for lack of jurisdiction. Petitioners should note that the Tax Court, unlike the Internal Revenue Service (IRS), does NOT recognize powers of attorney. It is further
ORDERED that the Clerk of the Court is directed to serve on petitioners with this Order a copy of the form previously served on petitioners February 12, 2024, that be used for purposes of ratifying the petition.