Opinion
19432-22L
02-07-2023
ROSALINDA MONTANO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On October 26, 2022, respondent filed a Motion to Dismiss on Grounds of Mootness and to Strike asserting that petitioner's tax liability for tax year 2014 has been paid in full subsequent to the filing of the petition in this case, and therefore, the proposed levy is no longer necessary as to tax year 2014. Respondent states in the motion to dismiss that petitioner does not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss on Grounds of Mootness is granted in that so much of this case as relates to a notice of determination concerning collection action for tax year 2014 is dismissed. Petitioner is reminded that so much of this case as relates to a notice of determination concerning collection action for tax years 2015 through 2018 remains pending before the Court.