Opinion
1640-22S
03-14-2023
DENNIS S. CUPUZ & EVANGELINE D. CAPUZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge
By Notice dated November 23, 2022, this case is calendared for trial at the Court's San Francisco, California trial session commencing on March 20, 2023. On February 27, 2023, respondent filed a Motion To Close On Ground of Duplication. Upon review of the records at Docket Nos. 1640-22S and 35641-21, the Court notes that the cases are duplicative. Both cases seek review of a Notice of Deficiency dated October 18, 2021, determining a deficiency and I.R.C. section 6662(a) additions to tax in petitioner's Federal income tax for the 2019 taxable year.
Accordingly, and for cause, it is
ORDERED that respondent's above-referenced motion is granted and the case at Docket No. 1640-22S is closed on the ground of duplication with the case at Docket No. 35641-21. All future filings concerning the Notice of Deficiency issued to petitioners for the 2019 taxable year shall be directed to the case at Docket No. 35641-21.