Opinion
1957-24S 1959-24S
04-08-2024
RYAN C. HOLLOWAY & ELIZABETH N. HOLLOWAY, ET AL Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 5, 2024, petitioners timely filed an imperfect Petition to commence the case at Docket No. 1957-24S. The filing fee for that case was not paid.
On February 5, 2024, petitioners also timely filed the Petition to commence the case at Docket No. 1959-24S. The filing fee for that case was paid.
On March 28, 2024, respondent filed at Docket No. 1959-24S a Motion to Close on Ground of Duplication, asserting that the cases at Docket Nos. 1957-24S and 1959-24S are duplicative. Respondent represents in his motion that petitioners have no objection to the granting of that motion.
Upon review of the records in the two above-referenced cases, it appears to the Court that the cases are duplicative and, therefore, one of the cases should be closed. However, as the case at Docket No. 1959-24S appears to be the more complete case at this time, we will deny respondent's motion and, on the Court's own motion, close the case at Docket No. 1957-24S.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Close on Ground of Duplication filed in the case at Docket No. 1959-24S is denied. It is further
ORDERED that, on the Court's own motion, the case at Docket No. 1957-24S is closed on the grounds of duplication. It is further
ORDERED that the caption of the case at Docket No. 1959-24S is amended to read: "Ryan C. Holloway and Elizabeth N. Holloway, Petitioners v. Commissioner of Internal Revenue, Respondent".
All future communications concerning the notice of deficiency issued to petitioners for their 2020 tax year shall be directed to the case at Docket No. 1959-24S.