Opinion
20064-21S
10-08-2021
Michelle Perez Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On April 29, 2021, the Court filed a letter from petitioner as an imperfect petition to commence the case at Docket No. 14226-21S. The Court's $60.00 filing fee was not paid. Accordingly, by Order served July 21, 2021, the Court directed petitioner to file a proper amended petition and pay the Court's filing fee. The Court attached to the foregoing Order a copy of an amended petition form that petitioner could use to comply therewith. Petitioner thereafter paid the Court's filing fee as directed.
On August 25, 2021, petitioner electronically filed a petition to commence this case. However, upon review, the Court notes that the petition consists of a copy of the Court's Order served July 21, 2021, in the case at Docket No. 14226-21S, and an amended petition form that petitioner has captioned in the name of "Michelle Perez" and under the docket number "14226-21". In the amended petition, petitioner seeks to challenge a purported notice of deficiency issued to her for the 2017 taxable year, the same year discussed in petitioner's petition at Docket No. 14226-21S.
On August 31, 2021, the Court received by U.S. Postal Service a paper copy of the just-described amended petition form that petitioner completed and electronically filed in this case. The Court filed the paper copy of the amended petition form as petitioner's First Amended Petition at Docket No. 14226-21S.
Based on the foregoing, it is clear to the Court that in electronically filing the petition in this case, petitioner's intention was to comply with the Court's Order served July 21, 2021, in the case at Docket No. 14226-21S, rather than to institute a new proceeding. Consequently, this case is a duplicate of the case at Docket No. 14226-21S, and we will close this case on the ground of duplication.
Upon due consideration and for cause, it is
ORDERED that, on the Court's own motion, this case is closed on the ground of duplication with the case at Docket No. 14226-21S. All future filings with respect to the purported notice of deficiency issued to petitioner for the 2017 taxable year shall be directed to the case at Docket No. 14226-21S.
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