Opinion
15032-21P
03-08-2022
Marilyn Shaff Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Albert G. Lauber Judge
In April 2021 the Commissioner certified to the Secretary of State that petitioner owed a seriously delinquent tax debt. See I.R.C. § 7345. In May 2021 petitioner timely petitioned this Court for review of the certification.
On March 4, 2022, respondent filed a Motion to Dismiss on Ground of Mootness. Respondent represents that, after the filing of the petition, the IRS notified the Secretary of State that petitioner's certification as an individual owing a seriously delinquent tax debt was erroneous and has been reversed. Because the certification has been reversed, respondent contends that there is no longer a justiciable case or controversy and that this case is moot. See Ruesch v. Commissioner, 154 T.C. 289 (2020), aff'd in part, vacated in part, 25 F.4th 67 (2d Cir. 2022). Petitioner does not object to the granting of respondent's Motion to Dismiss.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness, filed March 4, 2022, is granted, and this case is dismissed.