Opinion
25494-21
06-14-2022
CLYDE W. SCOTT & AMANDA G. SCOTT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan Chief Judge
On June 2, 2022, respondent filed a Motion to Close on Ground of Duplication on the ground that this case is a duplicate of the case at Docket No. 21968-21. Respondent states that petitioners' views on the Motion are unknown.
A review of the records at Docket Nos. 21968-21 and 25494-21 confirms that, as respondent asserts, those cases are duplicative: Both cases seek review of a Notice of Deficiency dated April 12, 2021, determining a deficiency and accuracy-related penalty in petitioners' federal income tax for the 2018 taxable year.
In view of the foregoing, and the fact that the Motion concerns a purely administrative matter that bears no impact on petitioners' substantive rights, we would ordinarily grant respondent's Motion forthwith. However, a review of the record at Docket No. 21968-21 shows that a stipulated decision was entered and served in that case on May 13, 2022. Consequently, the proper procedural mechanism by which to dispose of this case at this stage is dismissal.
Upon due consideration and for cause, it is
ORDERED that, on the Court's own motion, this case is dismissed on the ground of duplication with the case at Docket No. 21968-21. It is further
ORDERED that respondent's above-referenced Motion is denied as moot.