Opinion
23629-21L
06-05-2023
MATTHEW K. BARRINGER & BETSY T. BARRINGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan Chief Judge
This is a collection due process (CDP) case. On June 2, 2023, respondent filed a Motion to Dismiss on Ground of Mootness representing that the income tax liabilities at issue in this case have been paid in full by petitioners. Respondent asserts, therefore, that the proposed levy action is no longer necessary. Respondent also indicates that petitioners do not object to the granting of his motion. Because there is no longer any case or controversy to sustain the Court's jurisdiction over the tax years in question, this case is nonjusticiable and must be dismissed on the grounds of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006).
In view of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness is granted, and this case is dismissed as moot.