Opinion
23784-21L
03-03-2022
Elena N. Seavey Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On February 14, 2022, the Court filed a Letter by Petitioner. Therein, petitioner confirms that she remitted $175.00 (rather than $167.00, the payoff amount for petitioner's income tax liability for the 2018 taxable year that the Appeals Officer provided to petitioner during her collection due process hearing, according to the Notice of Determination upon which this case is based) to the United States Treasury to account for the interest that may have accrued between the date of the CDP hearing in this case and the date of remittance.
On February 22, 2022, respondent filed a Response to the Court's Order served February 4, 2022. Therein, respondent states that the $175.00 check that petitioner issued to pay off her balance for the 2018 taxable year may have erroneously been applied to an existing balance for the 2016 taxable year. Respondent concedes that, if this is the case, and the $175.00 payment is instead applied to petitioner's 2018 taxable year as she requested in the memo line of the check, this case will be rendered moot because petitioner's 2018 tax liability will have been paid in full. Respondent requests 60 days to obtain the administrative record for petitioner's 2016 taxable year and resolve this matter.
Upon due consideration of the foregoing, it is
ORDERED that, on or before May 2, 2022, the parties shall file a joint report regarding the then-present status of this case, or a joint motion to dismiss this case on the ground of mootness.