Opinion
23471-21L
04-22-2024
ERIC A. BEHRNDT & GAIL M. BEHRNDT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Patrick J. Urda, Judge.
On April 14, 2024, the parties filed a joint motion to dismiss on mootness grounds. The parties took the position that this case should be dismissed because the tax liability that is the subject of the notice of determination has been paid in full and that the Commissioner therefore no longer needs nor intends to levy to collect it.
Because there is no longer any case or controversy to sustain the Court's jurisdiction in this case, the action is no longer justiciable. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006).
Upon due consideration, it is
ORDERED that the joint motion to dismiss on ground of mootness is granted, and this case is dismissed on the ground of mootness.