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Boreyko v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 32016-21 (U.S.T.C. Aug. 3, 2022)

Opinion

32016-21

08-03-2022

OLESYA BOREYKO & ERICA SIVAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On January 20, 2022, respondent filed in this case a Motion to Close on Ground of Duplication. Respondent asserts in his motion that this case is a duplicate of petitioners' case at Docket No. 22077-21 as, in both cases, petitioners seeks review of a notice of deficiency, dated April 5, 2021, issued with respect to petitioners' 2018 tax year. On February 15, 2022, the Court entered its Order and Decision in Docket No. 22077-21 which decision is final. I.R.C. secs. 7481(a) (1), 7483. Upon review of the records in this case and the case at Docket No. 22077-21, respondent's motion appears well-supported in that both cases involve the same deficiency notice issued to petitioners for 2018..

In view of the foregoing, it is

ORDERED that respondent's above-described motion to close is denied. It is further

ORDERED that, on the Court's own motion, this case at Docket No. 32016-21 is dismissed for lack of jurisdiction on the ground the notice of deficiency for 2018 does not provide a basis for petitioners to invoke the Court's jurisdiction in Docket No. 32016-21.


Summaries of

Boreyko v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 32016-21 (U.S.T.C. Aug. 3, 2022)
Case details for

Boreyko v. Comm'r of Internal Revenue

Case Details

Full title:OLESYA BOREYKO & ERICA SIVAK, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Aug 3, 2022

Citations

No. 32016-21 (U.S.T.C. Aug. 3, 2022)