Opinion
8994-23L
03-27-2024
PAUL COUNTS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Patrick J. Urda Judge
This case was stricken from the Court's February 12, 2024, Seattle, Washington trial session and jurisdiction was retained by the undersigned.
Petitioner Paul Counts timely filed a petition in this case seeking review of a notice of determination concerning collection actions under sections 6320 or 6330 of the Internal Revenue Code.
Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times.
On December 14, 2023, the Commissioner filed a motion for summary judgment. On February 1, 2024, Mr. Counts filed a notice of concession in which he indicated that he does not object to the granting of this motion. In light of Mr. Count's representation, we will grant the Commissioner's unopposed motion for summary judgment and enter decision in this case. See also Wagner v. Commissioner, 118 T.C. 330 (2002) (noting that a CDP case may be dismissed upon motion by petitioner).
It is accordingly
ORDERED that the Commissioner's motion for summary judgment filed December 14, 2023, is granted. It is further
ORDERED and DECIDED that the determinations set forth in the notice of determination dated May 16, 2023, upon which this case is based, are sustained in full.