Opinion
15424-21
09-17-2021
Brandon Ryan & Kari-Ann Ryan Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On May 3, 2021, the Court filed an imperfect petition to commence this case. The petition was not properly executed in that it did not bear the original signatures of petitioners or of a practitioner admitted and recognized to practice before this Court, as required by the Tax Court Rules of Practice and Procedure. Accordingly, by Order served August 24, 2021, the Court directed petitioners to file a ratification of petition. To date, petitioners have not complied with the Court's Order.
On September 10, 2021, the parties filed a proposed stipulated decision resolving the underlying tax liability that is the subject of this proceeding. As the Court's procedures require all stipulated decisions to bear original signatures and the party who files the decision to maintain the paper copy, petitioners' intentions to file and prosecute the case in this forum have been adequately verified.
Upon due consideration of the foregoing, it is
ORDERED that, when the stipulated decision is entered in due course, the petition in this case, filed May 3, 2021, shall be deemed to have been ratified and affirmed by petitioners.
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