Opinion
7627-24P
08-19-2024
JOHN M. SMITH, JR. & REBECCA P. SMITH (APPLEGATE), Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Kathleen Kerrigan, Chief Judge.
On August 16, 2024, respondent filed a Motion to Dismiss on Grounds of Mootness asserting among other things that, subsequent to the filing of the petition underlying this passport proceeding, respondent notified the Secretary of State that petitioners' certification as individuals owing seriously delinquent tax debt for tax years 2006, 2008, 2009, and 2012 under section 7345 of the Internal Revenue Code had been reversed. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). Respondent states that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss on Grounds of Mootness is granted and this case is dismissed.