- 22 - would resolve certain relevant facts in this proceeding. Because we lack jurisdiction in this proceeding to determine petitioner’s 1992 overpayment or to order a refund or credit of petitioner’s 1992 taxes, and because the proposed collection action for 1992 is now moot, no factual issue remains which would affect the disposition of the case before us. For us to undertake to resolve issues that would not affect the disposition of this case would, at best, amount to rendering an advisory opinion. This we decline to do. Cf. LTV Corp. v. Commissioner, 64 T.C. 589, 595 (1975) (declining to provide an advisory opinion as to the amount of net operating losses (NOLs) in post-deficiency years in a deficiency case in which respondent had conceded NOLs sufficient to eliminate any deficiency for the year at issue). For the reasons discussed, we shall dismiss this case as moot. An appropriate order of dismissal will be entered. Reviewed by the Court. GERBER, COHEN, WELLS, HALPERN, CHIECHI, LARO, GALE, HAINES, GOEKE, KROUPA, and HOLMES, JJ., agree with this majority opinion. FOLEY, J., concurs in result only.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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