Opinion
7596-22L
08-25-2023
FESTUS O. OHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
This collection due process case is before the Court on respondent's Motion to Dismiss on Ground of Mootness the Portions of the Petition Related to Tax Year 2019, filed August 17, 2023. Therein, respondent states that an assessment of petitioner's federal income tax liability for tax year 2019 was abated in full, and that, consequently, respondent no longer needs or intends to levy to collect tax for that year. Respondent represents in his Motion that there is no objection to the granting thereof.
In view of these circumstances, we conclude that so much of this case as relates to tax year 2019 is moot and must be dismissed. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).
The foregoing considered, it is
ORDERED that respondent's above-referenced Motion to Dismiss is granted, and so much of this case as relates to tax year 2019 is hereby dismissed as moot. All references in the Petition to tax year 2019 are deemed stricken.
Petitioner is informed that so much of this case as relates to a notice of determination concerning collection action regarding a civil penalty for tax year 2017 remains pending before the Court.