Opinion
17666-21
02-14-2023
EDMUND A. PALMIERI & PAMELA C. PALMIERI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan Chief Judge
On November 10, 2021, respondent filed in the above-docketed case a Motion To Dismiss on Ground of Mootness. Therein, respondent moved to dismiss on the ground that, subsequent to the filing of the petition underlying this passport proceeding, respondent notified the Secretary of State that petitioners' certifications as individuals owing seriously delinquent tax debt for taxable years 2010 through 2017 under section 7345 of the Internal Revenue Code (I.R.C.) had been reversed. See Ruesch v. Commissioner, 154 T.C. 289 (2020), aff'd, 25 F.4th 67 (2022). Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.
The foregoing considered, it is
ORDERED that respondent's Motion To Dismiss on Ground of Mootness is granted, and this case is dismissed as moot.