Opinion
12679-20SL
04-04-2022
WILLIAM J. FINAMORE & HOPE M. FINAMORE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Peter J. Panuthos Special Trial Judge
Respondent's Motion to Dismiss On Ground of Mootness was filed on March 31, 2022. Respondent moves that this case be dismissed because the tax liability, including interest and penalties, which was the subject of the notice of Determination dated September 23, 2020, has been fully satisfied and, therefore, respondent does not intend to levy to collect for petitioner's tax liability for the tax periods ending December 31, 2013, December 31, 2014, December 31, 2015, and December 31, 2016. In his motion respondent asserts that petitioner has no objection to the granting of this motion.
On September 2, 2021, respondent filed a Motion For Summary Judgment. By Order dated October 22, 2021, the Court held the motion in abeyance in order to provide the parties an opportunity to continue settlement discussions. The Court will deny the motion as moot.
Premises considered, it is
ORDERED that respondent's Motion For Summary Judgment, filed September 2, 2021 is hereby denied as moot. It is further
ORDERED that respondent's Motion to Dismiss On Ground of Mootness, filed March 31, 2022, is granted and this case is hereby dismissed. 1