Opinion
12790-23L
10-02-2023
GINA MARIE DIAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Upon due consideration of the "Motion To Dismiss on the Grounds of Duplication", filed September 28, 2023, by respondent, and review of the records in the above-captioned case at Docket No. 12790-23L and that at Docket No. 12671-23, it has come to the attention of the Court that the just-cited cases represent a duplication of proceedings, both challenging a notice of determination issued to petitioner with respect to taxable years 2006, 2007, 2014, 2016, 2017, and 2018. However, Docket No. 12671-23 is an imperfect proceeding, with jurisdictional shortcomings and a less complete record, whereas Docket No. 12790-23L, where respondent filed the motion, is a proper and timely case.
Accordingly, upon due consideration of the foregoing and the records in the cases at Docket Nos. 12671-23 and 12790-23L, it appearing that the cases are duplicative, it is
ORDERED that respondent's just-referenced motion at Docket No. 12790-23L is denied. The Court on its own motion will issue an Order closing Docket No. 12671-23 on the ground of duplication.