Opinion
10146-19L
02-24-2023
JAY H. LEE AND PEI-LING LU, DECEASED, JAY H. LEE, SPECIAL ADMINISTRATOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Joseph H. Gale, Judge
This case has been assigned to the undersigned for disposition or other appropriate case management. The Petition in this case was filed in response to a Notice of Determination Concerning Collection Actions under I.R.C. Sections 6320 or 6330, issued by the Office of Appeals (Appeals) of the Internal Revenue Service on May 15, 2019. Therein, Appeals sustained the filing of a lien to collect petitioners' unpaid Federal income taxes for the 2009, 2010, 2011, 2012, and 2013 taxable years.
On January 3, 2023, respondent filed a Motion to Dismiss on Ground of Mootness seeking dismissal of the case on the ground of mootness because, subsequent to the filing of the Petition, petitioners had fully satisfied their Federal income tax liabilities for the years at issue. Respondent's Motion is supported by copies of petitioners' account transcripts for the years at issue, which reflect that no balances remain due and that the lien has been released.
In view of these circumstances, we conclude that the case is moot and must be dismissed. See Greene-Thapedi v. Commissioner, 126 T.C. 1, 7 (2006).
The foregoing considered, it is
ORDERED that respondent's Motion to Dismiss on Ground of Mootness filed January 3, 2023, is granted, and this case is hereby dismissed as moot.