Opinion
11432-20
12-27-2021
Robyn Louise Casal Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On June 17, 2019, respondent issued a notice of deficiency to petitioner for tax year 2013. On July 16, 2019, petitioner filed a timely petition at Docket No. 13207-19 seeking review of her 2013 tax year. On March 11, 2021, the Court entered an Order of Dismissal and Decision at Docket No. 13207-19. The Court's decision at Docket No. 13207-19 is now final. Sec. 7481(b).
On August 17, 2020, petitioner filed with the Court a second petition in which she again challenges her tax liability for 2013. Because petitioner previously challenged the notice of deficiency at Docket No. 13207-19, it follows that such notice does not provide a basis for petitioner to invoke the Court's Jurisdiction in this action, nor does the Court have the authority to vacate its decision, which is now final. See Abatti v. Commissioner, 859 F.2d 115, 117 (9th Cir. 1988), affg. 86 T.C. 1319 (1986). Finally, there is no indication that respondent issued any other notice of deficiency or notice of determination for 2013 that would permit petitioner to invoke the Court's jurisdiction for that year.
Upon due consideration of the records at Docket Nos. 13207-19 and 11432-20, it appearing that the cases are duplicative, it is
ORDERED that, on the Court's own motion, the case at Docket No. 11432-20 is dismissed on the ground of duplication with Docket No. 13207-19.