Opinion
2173-23
05-12-2023
ARNOLD MUGENYI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 20, 2023, 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 or of a representative with proper authorization and capacity pursuant to the Tax Court Rules of Practice and Procedure. Therefore, in order for this Court to acquire jurisdiction to consider this case, it is necessary to obtain a Ratification of Petition bearing petitioner's original signature and ratifying the petition previously filed.
By Order served March 1, 2023, the Court directed petitioner to so ratify the petition. A form for that purpose was provided for petitioner's use. To date, nothing has been received from petitioner. However, review of the record also shows that the initial Order was returned to the Court by the U.S. Postal Service as undeliverable, and petitioner's address has since been updated.
Accordingly, upon due consideration and to provide petitioner with a final opportunity to avoid dismissal of this case, it is
ORDERED that the time within which petitioner shall file a Ratification of Petition, bearing petitioner's original signature (preferably in blue ink) and ratifying the petition previously filed is hereby extended to June 12, 2023. If no such Ratification of Petition is received by that date, the Court may dismiss this case for lack of jurisdiction. Petitioner should note that the Ratification of Petition may NOT be filed electronically, and 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 petitioner with this Order a copy of the Court's proper Order served March 1, 2023, with accompanying form.