Opinion
4647-23L
03-11-2024
JONATHAN KOWALSKI & JENNAMARIE KOWALSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Emin Toro Judge
Petitioners filed a Petition in this case seeking review of a Notice of Determination Concerning Collection Actions Under IRC Sections 6320 or 6330, dated March 3, 2023, in which respondent sustained a proposed lien and levy action as to petitioners' 2016, 2017, and 2018 tax years. On March 6, 2024, respondent filed an unopposed Motion to Dismiss on Ground of Mootness (Doc. 10).
Respondent contends that this case should be dismissed as moot because "the income tax liabilities for taxable years 2016, 2017, and 2018 have been paid in full and the Federal tax lien, as well as the proposed levy, is no longer necessary." The Motion further provides that "the liens for 2016, 2017, and 2018 tax years are released."
Upon due consideration, it is hereby
ORDERED that respondent's Motion to Dismiss on Ground of Mootness filed March 6, 2024 (Doc. 10), is granted, and this case is dismissed as moot. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).