Opinion
10359-22
02-22-2023
LORI PATTILLO & ESTATE OF STEVEN B. PATTILLO, DECEASED, LORI PATTILLO, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 9, 2022, petitioners filed the petition to commence this case, seeking review of a notice of deficiency issued for petitioners' 2019 tax year. The petition indicates that petitioner Lori Pattillo is the executor of the Estate of Steven B. Pattillo, Deceased. However, petitioners did not attach to the petition any copy of letters testamentary, letters of administration, or an order issued by a court of competent jurisdiction demonstrating that Ms. Patillo is a legally authorized representative of decedent's estate. See Rule 60(c), Tax Court Rules of Practice and Procedure. On February 14, 2023, the parties filed a Proposed Stipulated Decision for the Corut's consideration.
Upon due consideration of the foregoing, it is
ORDERED that, on or before March 15, 2023, petitioners shall file a Response to this Order and attach thereto a copy of letters testamentary, letters of administration, or an order issued by a court of competent jurisdiction demonstrating that petitioner Lori Pattillo has been duly appointed as a representative of the Estate of Steven B. Pattillo, Deceased. The Court will hold the parties' Proposed Stipulated Decision pending submission of that response.