Opinion
8362-20W
07-26-2022
GEORGE UBERTI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On July 6, 2022, the Court entered in this case an Order and Order of Dismissal for Lack of Jurisdiction. On July 7, 2022, the Court entered in petitioner's case at Docket No. 15360-20W an Order and Order of Dismissal for Lack of Jurisdiction.
On July 19, 2022, petitioner filed in this case a motion to consolidate docket numbers 8362-20W, 15360-20W and a motion for reconsideration for finding of fact. In petitioner's motion to consolidate, petitioner requests that this Court consolidate the just-referenced cases for purposes of an appeal of the Court's rulings in those two cases. In petitioner's motion for reconsideration, petitioner requests that the Court make findings of fact in this case to aid in his appeal of this matter.
In relevant part Rule 141(a), Tax Court Rules of Practice and Procedure provides that "when cases involving a common question of law or fact are pending before the Court, it may * * * order all the cases consolidated * * *." As petitioner's above-referenced cases are no longer pending before this Court, however, we will deny petitioner's motion to consolidate. We also will deny petitioner's motion for reconsideration for finding of fact. This case was dismissed on the ground that the Court lacks jurisdiction and, therefore, the Court lacks authority to make any findings of fact in this case.
Upon due consideration of the foregoing, it is
ORDERED that petitioner's motion to consolidate docket numbers 8362-20W, 15360-20W is denied. It is further
ORDERED that petitioner's motion for reconsideration for finding of fact is denied.