Opinion
6473-24L
09-26-2024
SOLAS ELECTRICAL CONTRACTING SERVICES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
L. Paige Marvel, Judge.
On September 25, 2024, respondent filed a Motion to Dismiss on Ground of Mootness. In the motion, respondent moves to dismiss this case as moot given that petitioner's employment tax liabilities for tax periods June 30, 2021, and March 31, 2023, have been abated and paid, respectively. Therefore, respondent represents that he no longer intends to take collection action with respect to petitioner's employment tax periods ending June 30, 2021, and March 31, 2023, and that this case should be dismissed pursuant to Tax Court Rule 53. Petitioner does not object to the granting of the motion.
Because there is no longer any case or controversy to sustain the Court's jurisdiction over the tax periods in question, this case is nonjusticiable and must be dismissed on the ground of mootness. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006).
In consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness, filed September 25, 2024, is granted, and this case is dismissed as moot.