Opinion
21167-21S
08-21-2024
JILL PARKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Zachary S. Fried Special Trial Judge
This I.R.C. section 6015(e) case is before the Court on respondent's Motion to Dismiss on Ground of Mootness, filed July 24, 2024. In his motion, respondent represents that the 2013 tax liability, for which petitioner made a claim for relief pursuant to I.R.C. section 6015, has been paid in full by petitioner's former spouse. See Minihan v. Commissioner, 138 T.C. 1, 2 n.2 (2012) (where the entire joint liability has been paid, petitioner's request for section 6015 relief is moot, since the IRS will engage in no more collection activity, unless a refund is possible). Furthermore, petitioner does not contend that she is entitled to a refund for the year at issue.
On August 15, 2024, petitioner filed a document titled Objection to Motion to Dismiss on Ground of Mootness. A fair reading of petitioner's Objection, however, seems to support the relief requested in respondent's motion.
That being so, and for the reasons set forth in respondent's motion, it is
ORDERED that respondent's above-referenced Motion to Dismiss on Ground of Mootness is granted, and this case is dismissed as moot.