Opinion
19811-22
11-16-2022
RUBERT MARCANO & YARAIMA RODRIGUEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
By Order served September 22, 2022, the Court directed petitioners to file a ratification of petition. To date, no such ratification has been filed.
However, on November 15, 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. Review of the Proposed Stipulated Decision shows that the decision appears to be signed on behalf of respondent by an attorney who has not entered an appearance in this proceeding
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 August 31, 2022, shall be deemed to have been ratified and affirmed by petitioners. It is further
ORDERED that, on or before December 6, 2022, the attorney signing the Proposed Stipulated Decision for respondent shall file an Entry of Appearance in this case.