Opinion
4682-20L
10-14-2022
XIUQING QIU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Albert G. Lauber Judge
This is a collection due process (CDP) case. On February 20, 2020, the Internal Revenue Service (IRS or respondent) sent petitioner a notice of determination upholding a proposed levy for 2017, the tax year at issue. Petitioner timely petitioned this Court. On October 5, 2022, respondent filed a Motion to Dismiss on Grounds of Mootness. See Tax Court Rule 53. Respondent represents that he has abated the entire amount of petitioner's tax liabilities for the year at issue, and counsel for respondent represents that the IRS will take no further collection action against petitioner for the 2017 taxable year. Petitioner does not object to the granting of respondent's Motion to Dismiss.
As there is no remaining case or controversy to sustain this Court's jurisdiction, this action is no longer justiciable. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). We will therefore grant respondent's Motion to Dismiss on Ground of Mootness. In consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness, filed October 5, 2022, is granted and this case is dismissed.