Opinion
1175-23
03-31-2023
JUSTIN M. EBERT & JANINE M. EBERT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On March 2, 2023, respondent filed in this case a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. Respondent also states in his motion that this case is a duplicate of petitioners' case at Docket No. 27995-22 as, in both cases, petitioners seek to challenge a notice of deficiency, dated September 26, 2022, issued for petitioners' 2020 tax year. Upon review of the records in this case and petitioners' case at Docket No. 27995-22, it appears that the two cases are duplicative.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is denied. It is further
ORDERED that, on the Court's own motion, this case is closed on the grounds of duplication. All future communications concerning the notice of deficiency issued for petitioners' 2020 tax year shall be directed to the case at Docket No. 27995-22.