Opinion
28504-21
07-12-2022
LAWRENCE ALAN MARSHALL & DONNA MARIA MARSHALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
By Order served November 29, 2021, the Court directed petitioner Donna Maria Marshall to file a ratification of petition. To date, no such ratification has been filed.
However, on July 6, 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 Mrs. Marshall 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 August 23, 2021, shall be deemed to have been ratified and affirmed by petitioner Donna Maria Marshall.