Opinion
20203-21L
03-10-2022
Scott D. Miller & Karen E. Miller, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Courtney D. Jones Judge
This case is before the Court on a Notice of Determination Concerning Collection Action(s) Under Sections 6320 or 6330, dated July 28, 2021, for petitioners' taxable year 2017. On March 8, 2021, petitioners filed a Motion to Dismiss pursuant to Wagner v. Commissioner, 118 T.C. 330 (2002). Respondent filed a Notice of No Objection to petitioners' Motion to Dismiss March 9, 2022. In Wagner, the Court held that a lien or levy case may be dismissed upon motion by the petitioner where there is no prejudice to respondent.
After due consideration and for cause, it is
ORDERED that petitioners' aforementioned motion is granted and this case is dismissed.