Opinion
34476-21
02-09-2022
Kenneth M. Woodson & Dougette A. Woodson, Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Maurice B. Foley, Chief Judge
The petition in this case was filed on November 3, 2021. That petition seeks review of the notice of deficiency dated August 2, 2021, issued to petitioners for tax year 2018. That petition does not bear petitioners' original signatures, or the original signature of a practitioner admitted to practice before the Court, as required by the Tax Court Rules. Rather, that petition was apparently executed by John M. Pfeffer, petitioner's accountant (who is not admitted to practice before the Court). The Tax Court does not recognize powers of attorney.
On February 3, 2022, respondent filed a Motion To Strike Petition which the Court will recharacterize as respondent's Motion To Dismiss for Lack of Jurisdiction. Upon due consideration and for cause, it is
ORDERED that respondent's Motion To Strike filed February 3, 2022, is recharacterized as respondent's Motion To Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before March 9, 2022, petitioners shall file a ratification of petition ratifying and affirming the petition filed on their behalf in this case. Petitioners are reminded that ratification of petition may not be electronically filed, but must instead be filed in paper form and bear both their original signatures (preferably in blue ink). It is further
ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on petitioners in care of John M. Pfeffer at the address which Mr. Pfeffer listed for himself in the petition. It is further
ORDERED that the Clerk of the Court shall attach to the copies of this Order served on petitioners, a ratification of petition form which petitioners may use to ratify the petition.
RATIFICATION OF PETITION
We, Kenneth M. Woodson and Dougette A. Woodson, have read the Petition filed with the Court on November 3, 2021, and hereby ratify and affirm the filing of said document by affixing our signatures hereto.