Opinion
13864-20L
01-13-2022
Jessie L. Stuard & Olivia T. Stuard Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Travis A. Greaves, Judge
This case is calendared for trial during the Court's February 14, 2022, El Paso, Texas, remote trial session. On January 12, 2022, respondent filed a motion to dismiss on grounds of mootness. Respondent's motion states that the tax liabilities for taxable year 2015 have been paid in full and the proposed levy is no longer necessary. Respondent's motion further states that petitioners' counsel has no objection to the motion.
Because there is no longer any case or controversy to sustain the Court's jurisdiction, this action is no longer justiciable. See Greene-Thapedi v. Commissioner, 126 T.C. 1 (2006). Upon due consideration, it is
ORDERED that respondent's motion to dismiss on grounds of mootness is granted, and this case is dismissed as moot.