Opinion
25584-22SL
10-04-2023
SARANNA RAE HACK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Adam B. Landy Special Trial Judge
This collection due process case is calendared for trial at the Court's Standalone Remote Trial Session scheduled to commence on November 13, 2023.
On September 29, 2023, the Commissioner filed a Motion to Dismiss on Ground of Mootness on the basis that Ms. Hack has paid the liability in full for the tax years at issue. In the Commissioner's Motion, he states that Ms. Hack does not object to the Court granting his Motion. On October 3, 2023, Ms. Hack confirmed her non-objection to the Court granting the Motion.
Because there is no longer any case or controversy to sustain the Court's jurisdiction over the tax years at issue, this case is nonjusticiable and must be dismissed on the ground of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006).
Upon due consideration of the Commissioner's Motion, Ms. Hack's assent to the Court granting the motion, and for cause, it is
ORDERED that the Commissioner's Motion to Dismiss on Ground of Mootness, filed September 29, 2023, is granted and this case is hereby dismissed on the ground of mootness.