Opinion
5261-21
04-15-2024
MARY K. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
Upon review of the records in the above-captioned case at Docket No. 5261-21 and that at Docket No. 1856-21S, it has come to the attention of the Court that the just-cited cases represent a duplication of proceedings, both challenging a notice of deficiency/determination issued to petitioner with respect to taxable year 2017. Furthermore, a stipulated decision was entered in Docket No. 1856-21S on November 21, 2021, and is now final pursuant to section 7481(b) of the Internal Revenue Code.
Accordingly, upon due consideration of the foregoing and the records in the cases at Docket Nos. 1856-21S and 5261-21, it appearing that the cases are duplicative, it is
ORDERED that, on the Court's own motion, the case at Docket No. 5261-21 is dismissed on the ground that the notice of deficiency for 2017 does not provide a basis for petitioner to invoke the Court's jurisdiction in this action. See Abatti v. Commissioner, 859 F.2d 115, 117 (9th Cir. 1988), aff 'g 86 T.C. 1319 (1986).