Opinion
11830-21S
11-04-2021
Joyce S. Horton & Rodney L. Dye Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
Upon review of recent submissions by petitioners in the above-captioned case at Docket No. 11830-21S, and review of the record in this case and those at Docket Nos. 6070-21 and that at Docket No. 23752-21S, it has come to the attention of the Court that the just-cited cases represent a duplication of proceedings. Docket No. 6070-21 challenges a notice of deficiency issued petitioners for the taxable year 2017, while Docket No. 23752-21S challenges a notice of deficiency issued to petitioners for taxable year 2018. Both of those cases were timely filed as to their respective notices. The case at Docket No. 11830-21S attempts to challenge both 2017 and 2018, but it is not timely as to either notice, so cannot properly go forward as to either year, much less both as petitioner suggests.
Accordingly, upon due consideration of the foregoing and the records in the these cases, it appearing that the case at Docket No. 11830-21S is improper and duplicative of timely cases at Docket Nos. 6070-21 and 23753-21S, it is
ORDERED that, on the Court's own motion, the case at Docket No.11830-21S is closed on the ground of duplication.