Opinion
36265-21 1395-22
04-19-2022
Jason Brewer, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 6, 2021, the Court received from petitioner a letter, which was filed as a timely petition to commence the case at Docket No. 36265-21 in order to protect the taxpayer's interests to the extent possible. Attached to the petition is a notice of deficiency, dated October 4, 2021, issued for petitioner's 2019 tax year. The Court's $60.00 filing fee for that case has been paid.
On January 10, 2022, petitioner filed a second timely petition at Docket No. 1395-22, seeking review of the same notice of deficiency referenced above. The Court's $60.00 filing fee for that case has been paid.
On March 30, 2022, respondent filed in the case at Docket No. 1395-22 a motion to close on ground of duplication. As grounds, respondent asserts that Docket No. 1395-22 is a duplicate of petitioner's case at Docket No. 36265-21 inasmuch as petitioner seeks review in both cases of the same notice of deficiency. On April 4, 2022, petitioner submitted a document to the Court, which has been filed at Docket No. 1395-22 as petitioner's response to motion to close on ground of duplication. In his response, petitioner indicates that he prefers that Docket No. 36265-21 be closed and that Docket No. 1395-22 be permitted to remain pending before the Court.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion to close on ground of duplication, filed March 30, 2022, at Docket No. 1395-22 is denied. It is further
ORDERED that, on the Court's own motion, petitioner's case at Docket No. 36265-21 is closed on ground of duplication with petitioner's case at Docket No. 1395-22.