Geery v. Comm'r of Internal Revenue

Full title: PATRICIA GEERY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Dec 26, 2023

No. 15385-23 (U.S.T.C. Dec. 26, 2023)

Opinion

15385-23

12-26-2023

PATRICIA GEERY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

This is a collection case in which petitioner seeks review of a notice of determination concerning collection action issued for her 2015 tax year. On December 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, at the time the Petition was filed, respondent had not made any determination with respect to her 2015 tax year sufficient to confer jurisdiction on this Court. Respondent indicates that petitioner does not object to the granting of the motion to dismiss.

Like all federal courts, the Tax Court is a court of limited jurisdiction. As petitioner has not produced or otherwise demonstrated that, prior to the filing of the Petition in this case, respondent made any determination concerning her 2015 tax year that would permit petitioner to invoke the jurisdiction of this Court, we are obliged to dismiss this case for lack of jurisdiction.

Upon due consideration of the foregoing, it is

ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.