Opinion
36618-21L
05-31-2022
TOLBERT B. MARKS & SHARILYN R. MARKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MAURICE B. FOLEY, CHIEF JUDGE
Pending in the above-docketed matter is a Motion To Dismiss on Ground of Mootness as to 2014, 2015, and 2017, filed February 28, 2022, by petitioners herein. Subsequently, on March 22, 2022, respondent filed a response to such motion, and a first supplement to the response followed on May 4, 2022. In both submissions, respondent indicated that efforts to reapply payments to petitioners' various tax years, which could impact the concept of mootness in this proceeding, remained ongoing.
Accordingly, the premises considered, and to clarify the record herein, it is
ORDERED that, on or before June 24, 2022, respondent shall file a second supplement to the just-referenced response and shall advise as to the then-present status of petitioners' 2015 and 2017 tax years with respect to payments and mootness.