Opinion
7690-20L
12-09-2021
Barbara C. Becnel Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber, Judge.
This is a collection due process (CDP) case. On November 30, 2021, respondent filed a Motion to Dismiss on Ground of Mootness representing that petitioner made several payments in June, July, and September 2021 that resolved all outstanding income taxes, additions to tax, and interest with respect to petitioner's 2010 and 2012 tax years, the tax years in issue in this case. Therefore, respondent represents that he no longer intends to levy to collect petitioner's income tax liabilities and that this case should be dismissed pursuant to Tax Court Rule 53. Petitioner does not object to the granting of this Motion.
Because there is no longer any case or controversy to sustain the Court's jurisdiction over the tax years in question, this case is nonjusticiable and must be dismissed on the ground of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). In considera tion of the foregoing, it is
ORDERED that Respondent's Motion To Dismiss on Ground of Mootness, filed November 30, 2021, is granted, and this case is dismissed as moot.