Opinion
28935-21SL
02-22-2022
John J. Hoogendyk & Felisa Hoogendyk Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Maurice B. Foley, Chief Judge
On August 30, 2021, petitioners filed the petition to commence this case, seeking review of a notice of determination concerning collection action, dated August 2, 2021, issued with respect to their 2017 tax year. On December 21, 2021, respondent filed a Motion To Dismiss on Ground of Mootness asserting that petitioners' tax liabilities for 2017 have been fully paid and the proposed levy is no longer necessary. Although the Court directed petitioners to file an Objection, if any, to respondent's motion to dismiss, no response has been received from petitioners.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss on Ground of Mootness is granted and this case is dismissed on the ground of mootness.