Opinion
16218-21
10-01-2021
Douglas Sieger Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On September 24, 2021, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. However, review shows that the decision bears only a signature typewritten in a cursive font for petitioner, whereas Tax Court procedures require at minimum a digital image of an actual signature. Per the DAWSON guidance:
CAN I SUBMIT A DOCUMENT WITH A DIGITIZED SIGNATURE IN DAWSON?
Yes. Parties may submit a high-resolution or PDF document bearing either imaged or digitized signatures in satisfaction of the requirements of Rule 23(a)(3), Tax Court Rules of Practice and Procedure. Stylized signatures (e.g., signing with "/s" or using cursive font) are not acceptable.
Additionally, prior to entry of any stipulated decision, it is advisable to ensure that the record herein is complete insofar as concerns the documentation (1) relevant to establish the Court's jurisdiction over all parties and taxable periods and/or (2) referenced in the decision. Such is lacking here.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision, filed September 24, 2021, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before October 12, 2021, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2018 issued to petitioner.
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