Opinion
35867-21L
10-13-2022
LUCIUS W. WILLIAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 24, 2021, petitioner filed the petition to commence this case, seeking review of a notice of determination concerning collection action issued with respect to petitioner's 2006, 2007, 2009, 2012, and 2017 tax years.
On March 11, 2022, respondent filed a motion to dismiss on ground of mootness. Therein, respondent seeks dismissal of this case, insofar as it relates to petitioner's Federal income tax liabilities for the 2006 and 2007 taxable years, on the ground of mootness because petitioners tax liabilities for such years have been paid in full. Respondent represents therein that the tax lien with respect to those tax years is no longer necessary. Respondent attaches to his motion a copy of the account transcripts for 2006 and 2007, showing a zero balance for those tax years. By Order served April 15, 2022, the Court directed petitioner to file a response to the motion on or before May 6, 2022. Although the Court directed petitioner to file an objection, if any, to respondent's just-described motion, petitioner filed no such response.
In view of the circumstances, and for the reasons stated in respondent's above-described motion, the Court concludes that so much of this case as relates to 2006 and 2007 taxable years are moot and must be dismissed. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced motion is granted and so much of this case insofar as relates the 2006 and 2007 taxable years are hereby dismissed as moot and are deemed stricken from the Court's record in this case. Petitioner is advised that so much of this case as relates to the 2009, 2012, and 2017 taxable years remains pending before the Court.