Sewell v. Comm'r of Internal Revenue

Full title: JANICE LORRAINE SEWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: Jan 11, 2024

No. 25703-22L (U.S.T.C. Jan. 11, 2024)

Opinion

25703-22L

01-11-2024

JANICE LORRAINE SEWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Peter J. Panuthos Special Trial Judge.

ORDER

Peter J. Panuthos Special Trial Judge.

On July 28, 2023, petitioner's daughter Starsha M. Sewell filed a document titled, First Amendment to Entry of Appearance for Respondent. By Order served August 30, 2023, the Court recharacterized the document as Starsha Sewell's Motion to be Recognized as Next Friend.

On September 5, 2023, Starsha Sewell filed another document titled Motion to Be Recognized as Next Friend. By Order served October 12, 2023, the Court recharacterized the document as Starsha Sewell's First Supplemental Motion to Be Recognized as Next Friend.

On December 28, 2023, Starsha Sewell filed a document titled Motion to Be Recognized as Next Friend. The document also includes a motion to stay enforcement and a declaration.

The Court will recharacterize Starsha Sewell's Motion to Be Recognized as Next Friend, filed December 28, 2023, as Starsha Sewell's Second Supplemental Motion to Be Recognized as Next Friend and Motion to Stay Enforcement on the Basis of Respondent Mail Fraud & Affidavit in Support Under 28 U.S. Code § 1746. The Court will deny the motion insofar as it seeks to make a motion to stay enforcement.

ORDERED that the Motion to Be Recognized as Next Friend, filed December 28, 2023, is recharacterized as Second Supplemental Motion to Be Recognized as Next Friend and Motion to Stay Enforcement on the Basis of Respondent Mail Fraud & Affidavit in Support Under 28 U.S. Code § 1746. It is further

ORDERED that so much of the Second Supplemental Motion to Be Recognized as Next Friend and Motion to Stay Enforcement on the Basis of Respondent Mail Fraud & Affidavit in Support Under 28 U.S. Code § 1746, filed December 28, 2023 that seeks to "Stay Enforcement on the Basis of Respondent Mail Fraud & Affidavit in Support Under 28 U.S. Code § 1746" is denied. It is further

ORDERED that on or before January 30, 2024, respondent shall file a response to the Second Supplemental Motion to Be Recognized as Next Friend.