Opinion
24389-16L
03-24-2023
AGNES LUNN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan, Chief Judge.
On March 23, 2023, the parties filed a joint Motion to Dismiss on Ground of Mootness. The parties assert therein that, subsequent to the filing of the petition, petitioner's liability for I.R.C. §6672 penalties for the periods at issue has been paid in full and the proposed levy is no longer necessary. As there is no remaining case or controversy to sustain this Court's jurisdiction, this action is no longer justiciable. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006)
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness is granted and this case is dismissed.