Opinion
32129-21
06-22-2022
ORRICK M. BRIDGES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On November 30, 2021, petitioner filed the petition to commence this case. Petitioner indicates therein that he seeks review of tax years 2019 and 2020 and requests that the Court "order the IRS to accept [petitioner's minor child] as my dependent".
The Tax Court is a court of limited jurisdiction. It may therefore exercise jurisdiction only to the extent expressly provided by statute. Breman v. Commissioner, 66 T.C. 61, 66 (1976). No notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court is attached to the petition.
On April 11, 2022, respondent filed a motion to dismiss for lack of jurisdiction on the ground that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court as to tax years 2019 and 2020 was issued to petitioner. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, no response has been received from petitioner. Petitioner has not produced or otherwise demonstrated that he was issued any notice of deficiency or notice of determination sufficient to confer jurisdiction of this case on this Court.
Upon due consideration, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction is granted and this case is dismissed for lack of jurisdiction.