Opinion
25526-22
03-23-2023
NATHAN M. NAVARRO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On January 23, 2023, respondent filed a Motion To Close on Ground of Duplication in the above-captioned matter at Docket No. 25526-22, alleging that this proceeding was duplicative of the case at Docket No. 24872-22. However, the motion is inappropriate in the context in these proceedings, insofar as Docket No. 25526-22 raised only the year 2020, while the petition in Docket No. 24872-22 placed in issue taxable years 2018, 2019, 2020, 2021, and 2022. The case at Docket No. 24872-22 has also since been dismissed on jurisdictional grounds as untimely.
Accordingly, upon due consideration, it is ORDERED that respondent's Motion To Close on Ground of Duplication at Docket No. 25526-22 is denied.