Opinion
1167-24S 20343-23
07-10-2024
NICHOLAS B. LOKAI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On December 22, 2023, petitioner filed a timely petition at Docket No. 20343-23, seeking review of his 2021 tax year and paid the filing fee. On February 14, 2024, respondent filed the Answer at Docket No. 20343-23.
On January 22, 2024, petitioner filed a second timely petition at Docket No. 1167-24S also seeking review of his 2021 tax year and paid the filing fee. On March 13, 2024, respondent filed the Answer at Docket No. 1167-24S.
On June 14, 2024, respondent filed a Motion to Close on Ground of Duplication in the case at Docket No. 1167-24S. An examination of the records in the cases at Docket Nos. 20343-23 and 1167-24S discloses those two case are duplicative in that they involve the same notice of deficiency issued to petitioner for his 2021 tax year. Accordingly, the Court will move the petition filed in Docket No. 1167-24S and file it as an Amendment to Petition in Docket No. 20343-23 and grant respondent's motion to close in Docket No. 1167-24S.
The foregoing considered and for cause, it is
ORDERED that the Clerk of the Court shall remove the petition in Docket No. 1167-24S from the Court's official file in that docket and file it as an Amendment to Petition in Docket No. 20343-23 as of the date of this Order. It is further
ORDERED that the caption of the case at Docket No. 20343-23 is amended by adding the letter "S" to the docket number, and the Clerk of the Court shall process the case at Docket No. 20343-23 to trial or other disposition as a small Tax Court case. It is further
ORDERED that respondent's above-mentioned motion, filed in Docket No. 1167-24S on June 14, 2024, is granted in that the case at Docket No. 1167-24S is closed as duplicative of the case at Docket No. 20343-23.
Petitioner is reminded that any future filings related to his 2021 tax year should be filed in Docket No. 20343-23S.