Sandhu v. Comm'r of Internal Revenue

Full title: SALMAN I. SANDHU & RAKHSHINDA SANDHU, Petitioners v. COMMISSIONER OF…

Court: United States Tax Court

Date published: Apr 25, 2023

No. 3177-23 (U.S.T.C. Apr. 25, 2023)

Opinion

3177-23

04-25-2023

SALMAN I. SANDHU & RAKHSHINDA SANDHU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge.

ORDER

Kathleen Kerrigan Chief Judge.

The petition filed to commence this case served on March 13, 2023, 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 the Tax Court, as required by the Rule 23(a)(3), Tax Court Rules of Practice and Procedure. Petitioners' non-attorney representative who is not admitted to practice before this Court signed the petition on their behalf. The United States Tax Court, which is separate and independent from the IRS, has certain requirements that must be met before an individual can be recognized as representing petitioners before the Court. The Court has prepared Q&A's on the subject "Representing a Taxpayer Before the U.S. Tax Court. A copy of these Q&A's are attached to this order. The Court also encourages practitioners and non-attorneys seeking admission to practice before the Court to consult "Guidance for Practitioners" on the Court's website at www.ustaxcourt.gov/practitioners.html. At this juncture, petitioners' non-attorney representatives at Fareed Katariwala will not be associated with this case and we encourage petitioners' representative to review the Court's admissions requirements.

Therefore, in order for this Court potentially to acquire jurisdiction to consider this case, it is necessary to obtain a Ratification of Petition bearing petitioners' original signatures and ratifying the petition previously filed. Upon due consideration and for cause, it is

ORDERED that on or before June 13, 2023, petitioners shall file with the Court a Ratification of Petition ratifying and affirming the filing of the Petition on their behalf. It is further

ORDERED that the Clerk of the Court is directed to attach to this Order a form that petitioners may use to comply with this Order. It is further

ORDERED that the Clerk of the Court is directed to attach to the copy of this Order the Court's Q&As on the subject "Representing a Taxpayer Before the U.S. Tax Court". It is further

ORDERED that the Clerk of the Court shall serve a copy of this Order Fareed Katariwala at the address listed for him on the petition.