Opinion
22866-21SL
11-07-2024
DANIELLE SANGUINETTI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos, Special Trial Judge.
On November 4, 2024, respondent filed a Motion to Dismiss on Ground of Mootness. Therein, respondent requests that the Court dismiss this case as moot given that the income tax liabilities for taxable years 2014 and 2017 have been paid in full, that the civil penalty for taxable year 2013 has been fully abated, and that the proposed collection action is no longer necessary. Respondent represents that petitioner's views on the granting of the motion are unknown. The Court will give petitioner an opportunity to respond. The Court will be inclined to grant respondent's motion if petitioner does not file an objection or response to the pending motion.
Premises considered, it is
ORDERED that, on or before December 6, 2024, petitioner shall file a response to respondent's Motion to Dismiss on Ground of Mootness, filed November 4, 2024.