Opinion
18420-21
01-03-2022
Thomas Eric Watson Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 27, 2021, the Court received from petitioner in the above-docketed proceeding a letter/document which, although entitled "Motion To Dismiss", was in the nature of and will be recharacterized as a Motion for Entry of Decision. The document and an attached notice from the Internal Revenue Service (IRS) indicated that the case underlying this matter for taxable year 2018 had been resolved with the IRS. On that basis, petitioner requested that the instant proceeding be dismissed.
The following day, on December 28, 2021, the parties filed a Proposed Stipulated Decision resolving this litigation.
Accordingly, because the Tax Court cannot dismiss a deficiency case for reason other than lack of jurisdiction without entering a decision specifying the amount of tax due, and commensurate with entry of the decision, it is
ORDERED that petitioner's document filed December 27, 2021, shall be recharacterized as a Motion for Entry of Decision. It is further
ORDERED that petitioner's just-referenced Motion for Entry of Decision is granted.