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each of her taxable years 1993 through 1996 and that she is
entitled to a refund of such overpaid tax for each such year as
well as interest on each such claimed overpayment. Respondent
disputes petitioner’s position. However, it is respondent’s
position that the Court may not resolve that dispute. That is
because, according to respondent, the Court does not have juris-
diction (1) to determine whether there is an overpayment for each
of petitioner’s taxable years 1993 through 1996 or (2) to order a
refund or credit of tax for each such year.
We agree with respondent that this case is moot. Respondent
no longer claims that there is an amount of tax due from peti-
tioner with respect to any of her taxable years 1993 through
19964 and does not intend to pursue any collection action with
respect to any of those years. As for petitioner’s position that
there is an overpayment for each of those years for which she is
entitled to a refund, we agree with respondent that we do not
have jurisdiction in this proceeding to determine whether there
is an overpayment or to order a refund or a credit of tax for any
of those years. Greene-Thapedi v. Commissioner, 126 T.C. __
(2005). We shall dismiss this case as moot.5
4With respect to petitioner’s taxable year 1996, respondent
offset the amount of tax that respondent maintains is due from
petitioner (i.e., $1,143) with overpayments for 1999, 2002, and
2003. See sec. 6402(a).
5We have considered all of petitioner’s contentions and
(continued...)
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