Opinion
3066-24L 5807-24
05-23-2024
SHAWANIA MARSHALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 24, 2024, petitioner electronically filed a Petition to commence the case at Docket No. 3066-24L. On April 11, 2024, petitioner electronically filed a Petition to commence the case at Docket No. 5807-24. The Petitions filed in the two cases are identical copies of the same document; this document indicates that petitioner disputes, for tax years 2013, 2014, 2015, 2016, 2017, 2018, 2019, and 2020, a notice of determination concerning collection and a notice of final determination for disallowance of interest abatement claim (or failure of IRS to make final determination within 180 days after claim for abatement) issued on February 15, 2024.
On May 21, 2024, respondent filed a Motion to Close on Ground of Duplication in the latter-filed case, at Docket No. 5807-24. Therein respondent states that a notice of determination concerning collection action was mailed to petitioner on February 15, 2024. However, respondent did not attach a copy of this notice to his motion, nor is there a copy of the notice in the record in either of the above-docketed cases.
Upon due consideration of the above, and for cause, it is
ORDERED that, on or before June 12, 2024, respondent shall file, in both of the above-docketed cases, a status report, attaching thereto a copy of the notice of determination concerning collection action issued to petitioner on February 15, 2024, as well as any other notices issued to petitioner with respect to the taxable periods challenged in the Petition.