IRS Tried to Dismiss an E-Filed Petition Over the Signature. The Tax Court Said No.
The IRS argued an e-filed petition wasn't valid because it lacked a handwritten signature. The Tax Court disagreed.
In February 2025, the IRS tried to throw out a Tax Court petition filed by a married couple — not because of the merits, but because it didn't have a handwritten signature.
The Tax Court rejected that argument. If you've filed a petition using DAWSON's online petition generator, this case confirms your filing is valid.
What Happened
Robert and Kegan Donlan received a Notice of Deficiency dated July 22, 2024. They had until October 21, 2024, to file a petition with the Tax Court.
On that final day, they filed electronically using DAWSON — the Tax Court's online filing system. They used the petition generator, which creates a completed petition based on your answers to a series of questions.
Petitions created this way don't have handwritten signatures. Instead, they include a signature block with the taxpayer's name and contact information.
The IRS filed a Motion to Dismiss for Lack of Jurisdiction, arguing that because the petition wasn't signed by hand, the Tax Court had no authority to hear the case.
What the Court Said
The Tax Court denied the IRS's motion.
Judge Buch pointed to Rule 23(a)(3) of the Tax Court Rules of Practice and Procedure:
"A person's name on a signature block on a paper that the person authorized to be filed electronically, and that is so filed, constitutes the person's signature."
The court noted that petitions created with DAWSON's online generator include each taxpayer's name as part of a signature block. That satisfies the signature requirement.
The court also noted that other federal courts treat electronic signatures the same way. Under Federal Rule of Civil Procedure 5(d)(3)(C) and Federal Rule of Appellate Procedure 25(a)(2)(B)(iii), a filing made through a person's electronic-filing account, together with their name on a signature block, constitutes their signature.
What This Means for Pro Se Filers
If you file your Tax Court petition using DAWSON's online petition generator, your petition is properly signed. You don't need to print it, sign it by hand, and re-upload it.
The combination of your DAWSON login credentials and your name appearing in the signature block is enough.
This case is particularly important because the Donlans filed on the last possible day. If the IRS's argument had succeeded, they would have lost their right to challenge the deficiency entirely — not because they were wrong on the tax issues, but because of a procedural technicality.
The Tax Court didn't let that happen.
The Bigger Picture
The IRS has attorneys. Pro se taxpayers usually don't. When the IRS argues that a self-represented taxpayer's petition should be thrown out on a technicality — especially one related to the court's own e-filing system — it matters that the court pushes back.
The Tax Court designed DAWSON to make filing easier for people representing themselves. This opinion confirms that using the system as intended is sufficient.
Case Reference
Donlan v. Commissioner, 164 T.C. No. 3 (2025), Docket No. 16759-24
This article is for informational purposes only and does not constitute legal or tax advice. If you're facing an IRS dispute, consult a qualified professional about your specific situation.