Opinion
10643-22L
07-12-2024
DANIEL HSU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Maurice B. Foley Judge
On June 20, 2024, the Court filed respondent's Motion to Dismiss on Ground of Mootness stating that the income tax liability relating to the period ending December 31, 2018 has been voluntarily paid and petitioner did not Petition that liability; that the trust fund recovery penalties relating to the taxable periods ending September 30, 2016, December 31, 2016, and June 30, 2017 were abated by respondent as part of the supplemental notice of determination dated April 16, 2023; and that there no longer exists a case or controversy to sustain this Court's jurisdiction. On June 24, 2024, the Court ordered petitioner to file any objection on or before July 12, 2024. On July 11, 2024, the Court filed petitioner's Notice of No Objection to Respondent's Motion to Dismiss on Ground of Mootness stating that he had no objection to the granting of respondent's Motion.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness, filed June 20, 2024, is granted and this case is dismissed as moot.