Opinion
2503-21
10-20-2021
Luther S. Douglas Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On April 13, 2021, respondent filed in the above-captioned case at Docket No. 2503-21 a Motion To Close on Ground of Duplication, advising the matter represents a duplication of proceedings with the case at Docket No. 2366-21L, both challenging a notice of determination issued to petitioner with respect to taxable periods in 2011 and 2012. The case at Docket No. 2366-21L, however, had multiple jurisdictional shortcomings and was subsequently dismissed by Order of Dismissal for Lack of Jurisdiction entered August 11, 2021.
Accordingly, upon due consideration of the foregoing and to permit the case with the more complete jurisdictional record to proceed, it is
ORDERED that respondent's just-referenced motion is denied. It is further
ORDERED that the Clerk of the Court is directed to add the letter "L" to the docket record and other records of the Court and to process this case to trial or other disposition according to the Lien and Levy Action procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure. It is further
ORDERED that respondent shall file an answer to the petition in this case on or before November 19, 2021.