Opinion
18424-23L
09-17-2024
TIMOTHY JOHNSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Peter J. Panuthos, Special Trial Judge
This case is calendared for trial at the Court's Washington, D.C., trial session commencing November 4, 2024. On September 5, 2024, the parties filed a Joint Motion to Dismiss on Ground of Mootness, stating that this case is moot because petitioner's trust fund recovery penalty liabilities for the September 2015, March 2016, June 2016, and September 2016 tax periods have been paid in full, and the proposed levy is no longer necessary.
As there is no remaining case or controversy to sustain this Court's jurisdiction, this action is no longer justiciable. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). We will therefore grant the parties' Joint Motion to Dismiss on Ground of Mootness.
Upon due consideration, it is
ORDERED that the Joint Motion to Dismiss on Ground of Mootness, filed September 5, 2024, is granted, and this case is dismissed as moot.