Opinion
12516-20
03-11-2024
LORD QUINCY DOWDELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan Chief Judge
On October 23, 2020, petitioner filed a Petition seeking review of notices of determination concerning collection action purportedly issued for the taxable years 1982 through 2020. At this time, the only claims remaining before the Court relate to the taxable years 2002 through 2005. On March 22, 2023, respondent filed a Motion to Dismiss on Ground of Mootness for Tax Years 2002, 2003, 2004, and 2005. Therein, respondent moves that the remainder of this case be dismissed as moot on the grounds that the liabilities for the taxable years 2002 through 2005 have either been written off or satisfied, and that, consequently, respondent no longer needs nor intends to levy to collect them.
See Order (Feb. 14, 2023) (dismissing all other claims raised in the Petition for lack of jurisdiction on the ground that no such notices had been issued).
By Order served April 3, 2023, the Court directed petitioner to file an objection, if any, to respondent's Motion. That Order warned petitioner that failure to comply could result in the granting of the Motion to Dismiss. The Court twice thereafter extended the time for petitioner to file any objection-by Order served April 25, 2023, and Order served June 23, 2023-and again warned petitioner that failure to comply could result in the granting of the Motion to Dismiss. To date, no objection has been filed.
The record establishes that petitioner has no remaining tax liabilities for the taxable years before the Court. In view of these circumstances, we conclude that this case is moot and must be dismissed. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Motion to Dismiss is granted, and this case is dismissed as moot. It is further
ORDERED that respondent's Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed June 9, 2023, is denied as moot.