Opinion
3853-24P
07-18-2024
DANIEL JACOBY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan Chief Judge
On June 6, 2024, respondent filed in the above-docketed case a Motion To Dismiss on Ground of Mootness. Therein, respondent moved to dismiss on the ground that, subsequent to the filing of the petition underlying this passport proceeding, respondent notified the Secretary of State that petitioner's certification as an individual owing seriously delinquent tax debt for taxable year 207 under section 7345 of the Internal Revenue Code (I.R.C.) had been reversed. See Ruesch v. Commissioner, 154 T.C. 289 (2020), aff'd, 25 F.4th 67 (2022). Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.
The foregoing considered, it is
ORDERED that respondent's Motion To Dismiss on Ground of Mootness is granted, and this case is dismissed as moot.