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Fogle v. Comm'r of Internal Revenue

United States Tax Court
Mar 15, 2023
No. 9964-22 (U.S.T.C. Mar. 15, 2023)

Opinion

9964-22

03-15-2023

JASON R. FOGLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Travis A. Greaves Judge

On February 16, 2023, respondent filed in this case a Motion to Close on Ground of Duplication. Respondent asserts in his motion that this case is a duplicate of petitioner's case at Docket No. 10676-22 as, in both cases, petitioner seeks review of a notice of deficiency, dated February 7, 2022, issued with respect to petitioner's 2019 tax year.

Upon review of the records in this case and petitioner's case at Docket No. 10676-22, respondent's motion appears well-supported. However, the Court notes that a Stipulated Decision was entered and served in the case at Docket No. 10676-22 on July 29, 2022, and that decision is now final. See I.R.C. § 7481(b). Accordingly, the proper procedural mechanism by which to dispose of this case is dismissal for lack of jurisdiction.

Upon due consideration, it is

ORDERED that respondent's above-referenced motion is granted in that this case is dismissed for lack of jurisdiction.


Summaries of

Fogle v. Comm'r of Internal Revenue

United States Tax Court
Mar 15, 2023
No. 9964-22 (U.S.T.C. Mar. 15, 2023)
Case details for

Fogle v. Comm'r of Internal Revenue

Case Details

Full title:JASON R. FOGLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Mar 15, 2023

Citations

No. 9964-22 (U.S.T.C. Mar. 15, 2023)