Opinion
848-24 2796-24
02-23-2024
DALE I. SHAW & SUSAN A. SHAW, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 12, 2024, petitioners filed an imperfect petition to commence the case at Docket No. 848-24, seeking review of a notice of deficiency, dated October 2, 2023, issued for petitioners' 2021 tax year. The filing fee for that case was not paid.
By Order served January 18, 2024, the Court directed petitioners to file an Amended Petition and to pay the Court's filing fee. On February 20, 2024, without having properly requested and been issued electronic credentials for Docket No. 848- 24, petitioners apparently electronically filed their Amended Petition, resulting in the commencement of a separate case at Docket No. 2796-24 in which petitioners seek review of the same notice of deficiency described in the paragraph above. Thus, Docket No. 2796-24 is a duplicate of the case petitioners filed at Docket No. 848-24. The filing fee for Docket No. 2796-24 was paid.
Upon due consideration of the foregoing, it is
ORDERED that the Clerk of the Court shall copy the Petition filed on February 20, 2024, to commence the case at Docket No. 2796-24 and file it as of that same date as an Amended Petition at Docket No. 848-24. It is further
ORDERED that the filing fee paid at Docket No. 2796-24 shall be applied to Docket No. 848-24. It is further
ORDERED that, on the Court's own motion, the case at Docket No. 2796-24 is closed on the grounds of duplication. All future communications concerning the notice of deficiency issued for petitioners' 2021 tax year shall be directed to the case at Docket No. 848-24. It is further
ORDERED that, on or before April 22, 2024, respondent shall either file an Answer or move with respect to the Petition in the case at Docket No. 848-24.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you commenced your case in paper form and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you have not previously registered for eAccess, please do not attempt to electronically file documents in your case before first contacting dawson.support@ustaxcourt.gov to register for eAccess.