Opinion
5458-22
01-19-2023
GILLIAN DE BRUYN & NICHOLAS DE BRUYN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
The Tax Court is a court of limited jurisdiction, and we may exercise that jurisdiction only to the extent authorized by Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). Upon due consideration of the record of this case and for cause, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed June 16, 2022, is granted, and this case is dismissed for lack of jurisdiction. It is further
ORDERED that petitioners' Motion to Dismiss, filed January 12, 2023, is denied as moot.