Silver v. Comm'r of Internal Revenue

Full title: Kurt Ethan Silver Petitioner v. Commissioner of Internal Revenue Respondent

Court: United States Tax Court

Date published: Oct 28, 2021

20207-21S (U.S.T.C. Oct. 28, 2021)

Opinion

20207-21S

10-28-2021

Kurt Ethan Silver Petitioner v. Commissioner of Internal Revenue Respondent

Maurice B. Foley Chief Judge

ORDER

Maurice B. Foley Chief Judge

On August 25, 2021, the petition to commence this case was electronically filed. When a petition is electronically filed with the Court, the combination of the username and password of the individual efiling the petition serves as the signature of the filer. See DAWSON User Guides on the Court's website, www.ustaxcourt.gov. The petition in this case was electronically filed using petitioner Kurt Ethan Silver's username and password, and thus the petition is treated as having been properly executed and filed by Kurt Ethan Silver.

The petition also bears the signature of petitioner's spouse, Kelley C. Silver. However, the petition was not properly executed by Kelley C. Silver as her signature on the petition was made using a cursive computer font, which is not recognized by the Court as a proper imaged or digitized signature. Thus Kelley C. Silver will be required to file a Ratification of Petition, ratifying and affirming the petition filed to commence this case.

In view of the foregoing, it is

ORDERED that the caption of this case is amended to read: "Kurt Ethan Silver and Kelley C. Silver, Petitioners v. Commissioner of Internal Revenue, Respondent". It is further

ORDERED that, on or before November 17, 2021, petitioner Kelley C. Silver shall file a Ratification of Petition (see form attached) bearing her original signature (a "wet ink" signature, not a photocopy or made using a cursive computer font). Failure to comply with this Order may result in the dismissal for lack of jurisdiction of so much of this case relating to petitioner Kelley C. Silver. Petitioner should note that the Ratification of Petition may not be filed electronically. 1

Kurt Ethan Silver & Kelley C. Silver Petitioners

v.

Commissioner of Internal Revenue Respondent

RATIFICATION OF PETITION

I have read the petition received and filed by the Court on August 25, 2021, and hereby ratify and affirm the filing of that document by signing below. 2