Opinion
12149-22
07-13-2022
TAYLOR STRANGE & DANIELLE STRANGE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 2, 2022, the petition commencing 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 that individual. See the DAWSON User Guides on the Court's website, www.ustaxcourt.gov. The petition in this case was electronically filed using an email address belonging to jason@bourgetcpa.com and thus the petition is treated as having been signed by that individual. However, petitioners' non-attorney representative is not petitioner in this case nor is he a practitioner admitted to practice before this Court. It is well settled that, unless the petition is filed by the taxpayer or an individual who is lawfully authorized to act on the taxpayer's behalf, we are without jurisdiction. See Fehrs v. Commissioner, 65 T.C. 346, 348-349 (1975). The Tax Court, unlike the Internal Revenue Service, does not recognize powers of attorney. At this juncture, Jason Bourget will not be associated with this case and the email address used to electronically file the petition will be deleted from the record in this case.
The petition bore digital images of petitioners' signatures. As the Court's procedures require all petitions to bear original signatures of the taxpayers provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, petitioners' intention to file and prosecute this case in this forum has been adequately verified.
The Court has prepared Q&As on the subject "Representing a Taxpayer Before the U.S. Tax Court. A copy of these Q&As are attached to this Order. The Court 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. Petitioners are advised that they may represent themselves or seek representation by an individual who is admitted to practice before this Court. An individual admitted to practice before the Court will have an assigned Tax Court Bar number.
ORDERED that the Clerk of the Court shall make petitioners' service preference as paper in the record of this case. 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, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on Jason Bourget at the address listed on page 2 of the petition.