Opinion
13862-22L
08-30-2024
MATTHEW W. SANGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Emin Toro, Judge.
Petitioner filed a Petition in this case seeking review of a Notice of Determination Concerning Collection Actions Under IRC Sections 6320 or 6330, dated May 25, 2022, in which respondent sustained a proposed levy action as to petitioner's 2016, 2017, and 2018 tax years.
On August 28, 2024, respondent filed an unopposed Motion to Dismiss on Grounds of Mootness (Index no. 15). Respondent contends that this case should be dismissed as moot because "subsequent to the filing of the petition, the liabilities for taxable years 2016, 2017, and 2018, were paid in full."
Upon due consideration, it is hereby
ORDERED that respondent's Motion to Dismiss on Ground of Mootness filed August 28, 2024 (Index no. 15), is granted, and this case is dismissed as moot. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).