Opinion
3448-22
10-12-2022
LERON POLANI & MALI POLANI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
Petitioners commenced two cases in this Court, the first at Docket No. 3448-22, the instant case, and the second at Docket No. 8900-22. They paid the fee at Docket No. 8900-22 but not in the instant case, and accordingly, the Court dismissed this case for lack of jurisdiction on August 29, 2022. The case at Docket No. 8900-22, however, had been dismissed on June 2, 2022, on the ground of duplication with the instant case. A further review of the record reveals that petitioners failed to file a Ratification of Petition in the instant case as directed by Order issued May 10, 2022. Premises considered, it is
ORDERED that the Letter Dated September 5, 2022, is hereby recharacterized as petitioners' Motion to Vacate. It is further
ORDERED that petitioners shall, on or before November 1, 2022, file a Ratification of Petition. The Clerk of the Court shall attach to this Order a form which petitioners may use to ratify the petition filed January 31, 2022.
Petitioners' motion to vacate will be held in abeyance pending receipt of the ratification. Failure to file a ratification may result in the denial of the motion to vacate or other action as the Court deems appropriate.
RATIFICATION OF PETITION
___, have read the Ratification of Petition filed with the Court on ___ and do hereby ratify and affirm the fling of aid document by affixing my signature hereto.