Opinion
4925-24SL
08-13-2024
ROCHE EXCAVATING INC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 9, 2024, respondent filed a Motion to Dismiss on Ground of Mootness asserting that so much of this case relating to petitioner's taxable period ending June 30, 2021, is moot because petitioner's tax liability for that taxable period has been fully paid and the proposed levy is no longer necessary. Respondent states in his Motion that petitioner does not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness is recharacterized as a Motion to Dismiss on Ground of Mootness as to Taxable Period Ending June 30, 2021. It is further
ORDERED that respondent's above-referenced Motion is granted in that so much of this case relating to petitioner's taxable period ending June 30, 2021, is dismissed.