Opinion
8589-20L
10-06-2021
Ellen Palm-Leis Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Albert G. Lauber Judge
This collection due process (CDP) case was originally calendared on the Court's October 4, 2021, Los Angeles, California, trial session. In November 2018 the Internal Revenue Service (IRS or respondent) filed a notice of Federal tax lien covering petitioner's unpaid tax liabilities for 2011. Petitioner timely requested a CDP hearing, asking for the lien to be withdrawn. On February 24, 2020, the IRS issued petitioner a notice of determination sustaining the collection action.
Petitioner petitioned this Court in July 2020. On July 29, 2021, petitioner paid her outstanding tax liabilities for 2011. On August 5, 2021, respondent filed a motion for summary judgment. As of that date petitioner's account transcript had not yet reflected the payment. The IRS withdrew the tax lien six days later.
On October 1, 2021, respondent filed a Motion to Dismiss on Ground of Mootness. Respondent represents that this case is now moot because petitioner has paid her liabilities for 2011 and the lien has been withdrawn. Petitioner does not object to the granting of respondent's Motion. In consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness, filed October 1, 2021, is granted, and this case is dismissed. It is further
ORDERED that respondent's Motion for Summary Judgment, filed August 5, 2021, is denied as moot.
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