Opinion
9514-20L
12-18-2023
PRESTIGIOUS AGENCY, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth A. Copeland, Judge
This case is calendared for trial at the Trial Session of the Court scheduled to commence on January 16, 2024, in Lubbock, Texas.
On July 10, 2020, petitioners filed with the Court a Petition concerning two Notice(s) of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code, one for tax period ending September 2017 and one for tax period ending December 2014. On December 7, 2023, the parties filed with the Court a Joint Motion to Dismiss on Grounds of Mootness regarding the Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code for tax period ending September 2017, issued on March 5, 2020. The parties informed the Court that this case should be dismissed because petitioner has paid the underlying liability for tax period ending September 2017, and the proposed levy is no longer necessary.
Also on December 7, 2023, the parties filed with the Court a Proposed Stipulated Decision concerning the Notice of Determination for tax period ending December 2014.
Upon due consideration, and for cause, it is
ORDERED that the parties' Joint Motion to Dismiss on Grounds of Mootness, filed with the Court on December 7, 2023, is granted, in that this case is dismissed only as to the Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code for tax period ending September 2017.