Opinion
25385-21S
03-24-2022
Sherryl Pacella & Robert Pacella Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On January 10, 2022, respondent filed in this case a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. Respondent states that petitioners do not object to the granting of the motion.
Respondent also asserts in his motion that this case is a duplicate of petitioners' case at Docket No. 9985-21S as, in both cases, petitioners seek review of a notice of deficiency issued with respect to petitioners' 2017 tax year. Upon review of the records in this case and petitioners' case at Docket No. 9985-21S, the cases appear duplicative.
In view 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 ground of duplication with respect to petitioners' case at Docket No. 9985-21S. 1