Opinion
2601-22L
12-12-2023
MELISSA KAYE PEACOCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On December 1, 2023, docket entry 35, respondent filed with the Court a Motion to Dismiss on Ground of Mootness. Respondent's Motion requests, pursuant to T.C. Rule 53, that this case be dismissed as moot given that the tax liability for the tax years 2011, 2015, and 2018 have been fully satisfied. Attached therein to respondent's Motion as Exhibits A, B, C are readable account transcripts for Petitioner's 2011, 2015, and 2018 income tax accounts, respectively, which demonstrate that Petitioner's income tax liabilities for 2011, 2015, and 2018 have been satisfied. As there is no remaining case or controversy to sustain this Court's jurisdiction as to these liabilities, this action is no longer justiciable as to those tax years. Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). Accordingly, this case is moot, and the petition should be dismissed. Respondent's counsel attempted but was unable to ascertain Petitioners' views on the granting of this motion.
After due consideration and for cause, it is
ORDERED that, on or before December 29, 2023, petitioner shall file with the Court a response to respondent's Motion to Dismiss on the Ground of Mootness, filed December 1, 2023, docket entry 35.