Opinion
11589-21 37936-21L
03-10-2022
Deidre R. Whitfield Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
MAURICE B. FOLEY, CHIEF JUDGE
On April 5, 2021, petitioner filed the petition to commence the case at Docket No. 11589-21, seeking review of a purported notice of deficiency issued for her 2018 tax year.
On July 19, 2021, the Court received from petitioner a Letter Dated July 13, 2021, in which petitioner indicates that she seeks review of a notice of determination concerning collection action for her 2016 and 2017 tax years. Rather than opening a new case, that letter was inadvertently filed in petitioner's deficiency case at Docket No. 11589-21.
In view of the foregoing, it is
ORDERED that the Clerk of the Court shall copy petitioner's Letter Dated July 13, 2021, filed July 19, 2021, in the case at Docket No. 11589-21 and file it nunc pro tunc as of July 19, 2021, as the petition to commence a separate case at Docket No. 37936-21L. All future communication concerning the notice of determination issued to petitioner for her 2016 and 2017 tax years shall be directed to Docket No. 37936-21L. It is further
ORDERED that the petition at Docket No. 37936-21L is deemed ratified. It is further
ORDERED that Los Angeles, California is designated as the place of trial in the case at Docket No. 37936-21L.
ORDERED that, on or before March 31, 2022, petitioner shall pay the filing fee for the case at Docket No. 37936-21L (or submit for the Court's consideration an Application for Waiver of Filing Fee, which is available on the Court's website by clicking on "eFiling & Case Maintenance", then by clicking on "Case Related Forms"). Instructions on how to pay the filing fee can be found in the "Guidance for Petitioners" tab of the Court's website at www.ustaxcourt.gov. It is further
ORDERED that petitioner's Letter Dated July 13, 2021, filed on July 19, 2021, in the case at Docket No. 11589-21, is stricken from the Court's record and shall not be viewable in that case.