Opinion
12187-21L
01-04-2024
JENNIFER KATHLEEN COOPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Patrick J. Urda Judge
This case is currently calendared on the Court's Spokane, Washington trial session, scheduled to begin February 15, 2024.
On December 28, 2023, the Commissioner filed a motion to dismiss on ground of mootness therein requesting that the Court dismiss this case as moot given that, subsequent to the filing of the petition, the tax and penalties at issue have been paid in full and the proposed levy is no longer necessary for tax year 2010. The Commissioner also states that petitioner Jennifer Kathleen Cooper does not object to the granting of this motion.
Because there is no longer any case or controversy to sustain the Court's jurisdiction concerning collection action for the tax year at issue, this case is nonjusticiable and must be dismissed on grounds of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). That being so, it is
ORDERED that the Commissioner's motion to dismiss on ground of mootness [Doc. 21] is granted, and this case is dismissed as moot.