Opinion
17836-23S
11-21-2023
JEFFREY J. WHALEY & TERESA F. WHALEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
The petition filed to commence this case was served on November 3, 2023, bore the signatures of petitioners in accordance of Rule 23(a)(3), Tax Court Rules of Practice and Procedure. It appears that petitioners' non-attorney representative, James L. Tyler who is not admitted to practice before the Court also signed the petition. The United States Tax Court, which is separate and independent from the Internal Revenue Service, has certain requirements that must be met before an individual can be recognized as representing petitioners before the Court. Unlike the IRS, the Court does not recognize powers of attorneys and, thus, petitioners' non-attorney representative may not represent them in this case. The Court has prepared Q&A's on the subject "Representing a Taxpayer Before the U.S. Tax Court". The Court also 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. At this juncture, James L. Tyler will not be associated with this case and we encourage petitioners' representative to review the Court's admissions requirements.
Upon due consideration and for cause, it is 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 James L. Tyler at the address listed for him on page 2 in the petition.