Opinion
24606-21S
11-16-2022
ANGELA M. WELLS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE
By Order served October 21, 2021, the Court directed petitioner to file a ratification of petition. To date, no such ratification has been filed. However, on November 14, 2022, the parties filed a Proposed Stipulated Decision, resolving the underlying tax liability that is the subject of this proceeding. Insofar as the Court's procedures require a stipulated decision to bear the original signature of the taxpayer, provided at minimum to the filing party as a high-resolution digital image and so maintained by the filing party, the intention of petitioner to file and prosecute the case in this forum has been adequately verified.
Upon due consideration and for cause, it is
ORDERED that, when the Stipulated Decision is entered in due course, the Petition in this case, filed July 6, 2021, shall be deemed to have been ratified and affirmed by petitioners.