Opinion
13598-23S
09-18-2024
DANIEL MURDOCK HOAK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
EMIN TORO JUDGE
This stand-alone I.R.C. § 6015 case is currently calendared for trial during the Court's February 3, 2025, Hartford, Connecticut, trial session. The Petition challenges a Notice of Determination Concerning Relief from Joint and Several Liability Under Section 6015, dated July 20, 2023, denying petitioner's request for relief under I.R.C. § 6015(b), (c), and (f) with respect to his joint and several Federal income tax liability for 2019. On September 12, 2024, the parties filed a Joint Motion to Dismiss on the ground of mootness. The parties move the Court to dismiss the case as moot because, "[a]t the time petitioner made his claim for relief pursuant to I.R.C. § 6015, the underpayment of tax for 2019 had been paid in full." The Motion further provides "[p]etitioner no longer wishes to pursue his claim for relief pursuant to I.R.C. § 6015."
Given the posture of the case, a stand-alone I.R.C. § 6015 proceeding in which the liability has been fully satisfied and in which petitioner does not object to the dismissal of the case, the Court will grant the parties' Joint Motion. Cf. Davidson v. Commissioner, 144 T.C. 273, 276-79 (2015). Upon due consideration, it is hereby
ORDERED that the parties' Joint Motion to Dismiss filed September 12, 2024, is granted and this case is dismissed on the ground of mootness.