Opinion
1073-22
02-21-2024
DOROTHY PURCELL, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Ronald L. Buch Judge
This is one of three transferee liability cases that appear to be related. The three cases are James M. Meyer v. Commissioner, no. 1072-22, Dorothy Purcell v. Commissioner, no. 1073-22, and Christopher Meyer v. Commissioner, no. 1077-22. The Court recently denied a Motion for Summary Judgment that was filed in docket no., 1077-22. See T.C. Memo. 2024-15.
These three transferee liability cases likely involve common questions of law and fact. If so, to avoid unnecessary costs, delay, or duplication, they should be consolidated. Rule 141(a). Notably, the requested places of trial in these cases are Miami, FL, Philadelphia, PA, and Washington, DC, respectively. For the Court to consider whether to consolidate these cases, it is
ORDERED that, by March 15, 2024, the parties shall file a response to this Order to Show Cause setting forth any objection to the Court's consolidating of these cases along with the reasons therefore. Regardless of the position taken with respect to consolidation, the response shall include a recommendation as to place of trial for these cases, if consolidated.