Opinion
4521-20L
03-10-2022
Joseph Arthur Mbacho Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Patrick J. Urda, Judge.
This collection due process (CDP) case was stricken from the Court's September 20, 2021, San Diego, California, remote trial session, and jurisdiction was retained by the undersigned.
On March 4, 2022, the Commissioner filed an unopposed motion to dismiss on ground of mootness stating that subsequent to the filing of the petition, the tax liabilities for taxable years 2002, 2003, 2004, 2008, 2010, 2011, and 2013 have been paid in full and the federal tax lien has been removed. Because there is no longer any case or controversy to sustain the Court's jurisdiction over the tax years in question, this case is nonjusticiable and must be dismissed on the ground of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006).
Upon due consideration, it is
ORDERED that the Commissioner's motion to dismiss on ground of mootness is granted, and this case is dismissed as moot.