Opinion
6218-23
08-21-2023
RAYMOND LEE JARDOT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
No notice sufficient to confer jurisdiction upon the Court was attached to the petition filed April 4, 2023, or to the amended petition filed June 9, 2023. On August 1, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice sufficient to confer jurisdiction upon the Court in this case was issued to petitioner. Petitioner filed an objection to the motion on August 17, 2023, but did not dispute the jurisdictional allegations made in respondent's motion.
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). Accordingly, and for the reasons set forth in respondent's motion, it is
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction.