Opinion
6660-24 9291-24
07-12-2024
ADAMA SOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 8, 2024, respondent filed a Motion to Close on Ground of Duplication in the case at Docket No. 9291-24. Therein, respondent asserts that the foregoing case is a duplicate of the case at Docket No. 6660-24, insofar as both cases seek review of the same notice of deficiency issued to petitioner on or about April 15, 2024, for the taxable year 2022. A review of the records in these cases confirms that, as respondent asserts, the cases are duplicative. However, at this time the record in the case at Docket No. 9291-24 is better developed. We will therefore take appropriate action as set forth below.
Upon due consideration and for cause, it is
ORDERED that the Order of Dismissal for Lack of Jurisdiction entered in the case at Docket No. 6660-24 on June 20, 2024, is hereby vacated and set aside. It is further
ORDERED that, on the Court's own motion, the case at Docket No. 6660-24 is closed on the ground of duplication with the case at Docket No. 9291-24. All future filings relating to the notice of deficiency issued to petitioner for the taxable year 2022 shall be directed to the case at Docket No. 9291-24. It is further
ORDERED that respondent's above-referenced Motion to Close on Ground of Duplication is denied as moot. It is further
ORDERED that respondent shall have 60 days from the service date of this Order within which to file an answer to petitioner's First Amended Petition filed in the case at Docket No. 9291-24 on July 1, 2024.