Opinion
1357-21L
04-29-2022
SUSAN M. LAFERRERA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
In this CDP case the Commissioner determined that petitioner Susan M. LaFerrera did not owe the liabilty that had been assessed against her and that had been the occasion for the notice of lien filed against her. The Commissioner therefore arranged for the liability to be abated and for the lien to be "released" pursuant to section 6325. When those acts had been accomplished, the Commissioner filed a motion to dismiss the case on grounds of mootness. In a telephone conference among the parties and the Court on April 14, 2022, Ms. LaFerrera inquired whether the Commissioner could obtain a "withdrawal" of the lien pursuant to section 6323(j). On April 28, 2022, the Commissioner filed a first supplement (Doc. 13) to his motion dismiss on grounds of mootness, showing that the lien has now been "withdrawn". The Court appreciates the prompt work of respondent's counsel. It is
ORDERED that, no later than May 16, 2022, Ms. LaFerrera shall file a response to the Commissioner's motion to dismiss, as supplemented, stating whether she objects to the granting of the motion and, if so, on what basis.