Opinion
35726-21 37604-21
06-13-2022
GALE DICKERSON JAMISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 14, 2022, respondent filed a Motion to Close on Ground of Duplication in the case at Docket No. 37604-21, requesting that the case be closed on the ground that it is a duplicate of the case at Docket No. 35726-21. Respondent states therein that petitioner's views on the Motion are unknown.
A review of the records at Docket Nos. 35726-21 and 37604-21 confirms that, as respondent asserts, those cases are duplicative: The Petitions in the cases, which the Court notes are substantively identical, were both filed in response to a Notice of Deficiency dated October 12, 2021, determining a deficiency and accuracy-related penalty in petitioner's federal income tax for the 2018 taxable year. In view of the foregoing, and the fact that the Motion concerns a purely administrative matter that bears no impact on petitioner's substantive rights, the Court would ordinarily be inclined to grant respondent's Motion forthwith. However, at this time the Court finds that the record in the case at Docket No. 37604-21 is better developed. Accordingly, we will deny respondent's Motion and instead close the case at Docket No. 35726-21 on our own motion.
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Motion to Close on Ground of Duplication is denied. It is further
ORDERED that, on the Court's own motion, the case at Docket No. 35726-21 is closed on the ground of duplication with the case at Docket No. 37604-21. All future filings with respect to the Notice of Deficiency issued to petitioner for the 2018 taxable year shall be directed to the case at Docket No. 37604-21.