Opinion
34893-21
04-22-2022
JONATHAN SAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction as to Taxable Years 2018 and 2020, filed February 11, 2022, by respondent in the above-docketed case, it is
ORDERED that, on or before May 19, 2022, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to 2018 and 2020 or other appropriate action by this Court. The case as to 2019 is not affected by respondent's motion and will continue before the Court, provided petitioner files a Ratification of Petition bearing his original signature. It is further
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 May 19, 2022. 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. The Ratification of Petition should be a separate document from any objection to the motion.