Rogers v. Comm'r of Internal Revenue

Full title: WILLIAM ROGERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jun 10, 2022

No. 30184-21 (U.S.T.C. Jun. 10, 2022)

Opinion

30184-21

06-10-2022

WILLIAM ROGERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge

ORDER

Kathleen Kerrigan, Chief Judge

Upon further review of the record in this case, the Court notes that the Petition, filed September 14, 2021, has not been properly executed, insofar as it has not been signed by petitioner or a practitioner admitted to practice before this Court, as required by the Tax Court Rules of Practice and Procedure.

However, on June 7, 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, petitioner's intentions 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 shall be deemed to have been ratified and affirmed by petitioner.