Opinion
20392-21L
02-01-2024
CAROLYN FELTNER & RONNIE FELTNER, DECEASED, CAROLYN FELTNER, SPECIAL ADMINISTRATOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
James S. Halpern Judge
On January 26, 2024, the parties' filed a joint Motion to Dismiss on Ground of Mootness (Motion). The parties assert therein that, subsequent to the filing of the petition, the I.R.C. § 6651(a)(2) failure to pay addition to tax for the 2018 taxable year has been abated in full, generating an overpayment (not including interest) in the amount of $1,930.26 and the proposed levy is no longer necessary. Accordingly, the Court is without jurisdiction as to this period and the case should be dismissed. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). Therefore, it is
ORDERED that the joint Motion is granted, and this case is dismissed as moot.