Opinion
5854-21P
02-15-2023
KEITH M. PHILLIPS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge.
The Petition filed to commence this case on May 3, 2021, raises two causes of action, seeking review of both (1) a Notice of Deficiency issued to petitioner on or about September 24, 2018, determining a deficiency in, and additions to, his Federal income tax for the taxable year 2014; and (2) a Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the State Department issued to petitioner on or about May 3, 2021, with respect to his outstanding Federal income tax liability for that same taxable year.
Upon due consideration of the record, and in view of the issues raised by the parties in their subsequent filings in this case, it appears to the Court that the interests of justice would be best served if these two causes of action were severed. See Rule 34(a), Tax Court Rules of Practice and Procedure.
Accordingly, it is
ORDERED that, on or before March 8, 2023, each party shall show cause in writing why so much of this case as seeks review of the Notice of Deficiency issued to petitioner for the taxable year 2014 should not be severed and assigned a new docket number such that a separate case may be maintained with respect to that Notice. 1