Opinion
18984-23L 18986-23L
01-11-2024
CHRISTOPHER BRAZZANO & REBECCA BRAZZANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 2, 2023, petitioners electronically filed the Petition to commence the case at Docket No. 18984-23L. On the same date, petitioners also electronically filed the Petition to commence the case at Docket No. 18986-23L. Both cases seek review of the same notice of determination concerning collection action (notice) dated November 3, 2023, sustaining a lien filing to collect petitioners' unpaid federal income tax liabilities for the 2018, 2019, and 2020 taxable years. Petitioners were issued individual copies of the notice, which were mailed to their joint address.
On December 5, 2023, the Court issued an Order to Show Cause why the case at Docket No. 18984-23L should not be closed on the ground of duplication with the case at Docket No. 18986-23L. On December 2, 2024, petitioners filed a response to the Court's Order. Therein petitioners stated they believed "that if an appeal [to Tax Court] was not interposed as to each Notice of Determination, then Respondent could and would later argue waiver as to each and every particular Notice of Determination."
Here, both cases involve the same two petitioners seeking review of the same notice of determination. These cases are thus duplicated.
It is accordingly
ORDERED that the Court's Order to Show Cause, issued December 5, 2023, is made absolute. It is further
ORDERED that the case at Docket No. 18984-23L is closed on the ground of duplication with the case at Docket No. 18986-23L.