Opinion
24633-22S
09-28-2023
JAYNE RENAE ENGLISH, PETITIONER & JAMES M. ENGLISH, SR., INTERVENOR, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
PATRICK J. URDA JUDGE
This case is currently calendared on the Court's Cleveland, Ohio trial session, scheduled to begin October 2, 2023.
On September 27, 2023, the Commissioner and petitioner Jayne Renae English filed a motion to dismiss on ground of mootness. In the motion, they stated that at the time Ms. English made her claim for relief under I.R.C. section 6015, there was an understatement of tax due for the taxable year 2018. The motion further states, however, that since the filing of the petition, intervenor James M. English has paid the outstanding liability for tax year 2018, therein rendering Ms. English's claim for relief from joint and several liability in this case as moot.
Additionally, the motion indicated that counsel for the Commissioner spoke with intervenor Mr. English and he has no objection to the granting of this motion.
Upon due consideration, it is
ORDERED that the joint motion to dismiss on ground of mootness is granted, and that this case is dismissed as moot.