(a) A party may request that the ALJ consolidate or
join two or more cases docketed at SOAH. See §1.20 of this title
(relating to Docketing Oral and Written Submission Hearings). Hearings
may be consolidated or joined if they involve the same taxpayer, or
if they involve more than one taxpayer with common issues of law or
fact, when a consolidated or joint hearing will promote the fair and
efficient handling of the matters. See 1 TAC §155.155(c). The
ALJ may issue an order consolidating or joining the cases absent a
request by a party and without prior notice to the parties. Consolidation
or joinder may not be ordered where the result would be the release
of confidential taxpayer information to another taxpayer who is not
otherwise entitled to the information in violation of Government Code,
§2003.104 (Confidentiality of Tax Hearing Information), Tax Code,
§111.006 (Confidentiality of Information), or any other statutory
provision protecting confidential taxpayer information.
(b) Where two or more cases have been consolidated
or joined for purposes of hearing, a party may request that the ALJ
sever the cases. The ALJ may issue an order severing the cases if
separate hearings will promote the fair and efficient handling of
the matters.
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