Opinion
18984-23L 18986-23L
12-05-2023
CHRISTOPHER BRAZZANO & REBECCA BRAZZANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge.
On December 2, 2023, petitioners electronically filed the Petition to commence the case at Docket No. 18984-23L. The Petition seeks review of a notice of determination concerning collection action dated November 3, 2023, sustaining a lien filing to collect petitioners' unpaid federal income tax liabilities for the 2018, 2019, and 2020 taxable years.
On the same date, petitioners also electronically filed the Petition to commence the case at Docket No. 18986-23L. However, that case appears to seek review of the same notice of determination concerning collection action for which the Petition was filed at Docket No. 18984-23L. Indeed, it appears to the Court that the Petition at Docket No. 18984-23L and the Petition at Docket No. 18986-23L are nearly identical, with the only apparent differences being (1) that the caption on the Petition at Docket No. 18986-23L includes the name of petitioner Rebecca Brazzano, and (2) that the copy of the notice attached to the Petition at Docket No. 18984-23L is addressed to petitioner Christopher Brazzano, whereas the copy attached to the Petition at Docket No. 18986-23L is addressed to petitioner Rebecca Brazzano. In view of the foregoing, it appears to the Court that these cases are duplicative, and that the appropriate action at this juncture would be to close the case at Docket No. 18984-23L on the ground that it is a duplicate of the case at Docket No. 18986-23L. It is accordingly
ORDERED that, on or before January 2, 2024, petitioners shall show cause in writing why the Court should not close the case at Docket No. 18984-23L on the ground of duplication with the case at Docket No. 18986-23L. Failure to comply with this Order may result in the closure of the case at Docket No. 18984-23L on such ground.