Opinion
28454-21L
11-30-2022
CLIFFORD EDWARD BARNES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Albert G. Lauber Judge
This collection due process (CDP) case is calendared on the Court's December 19, 2022, Washington, D.C., trial session. On November 28, 2022, the parties filed a joint Motion to Dismiss on Grounds of Mootness. In this motion, the parties represent that petitioner has fully paid the 2014, 2015, and 2016 Federal income tax liabilities that were the subject of the collection action and that respondent will take no further collection action against petitioner for these years.
Because there is no longer any case or controversy to sustain the Court's jurisdiction concerning collection action for the tax years at issue, this case is non justiciable and must be dismissed on grounds of mootness. See Green-Thapedi v. Commissioner, 126 T.C. 1 (2006). In consideration of the foregoing, it is
ORDERED that the parties joint Motion to Dismiss on Grounds of Mootness is granted, and this case is dismissed on the grounds of mootness.