Opinion
1353-21L
03-31-2022
MICHAEL J. MATTHEWS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Ronald L. Buch Judge
On November 4, 2021, the Court granted the parties' Joint Motion to Remand and this case was stricken from the Court's December 6, 2021, New Orleans, Louisiana remote trial session. On March 24, 2022, the Commissioner filed a status report informing the Court that the parties "had entered into an Installment Agreement for the unpaid income tax liabilities at issue in this case." The Supplemental Notice of Determination states: "The mailing of the Notice of Intent to Levy was appropriate when issued, but the proposed levy action is not sustained since an installment agreement is being granted by the Independent Office of Appeals." Since the parties have entered into an installment agreement, then this case would likely be rendered moot. To obtain the parties views, it is
ORDERED that, by April 27, 2022, the parties shall show cause why this case should not be dismissed as moot.