Opinion
35868-21
06-13-2022
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
Petitioner filed a petition to commence the instant case on November 29, 2021. As respondent explained in the Motion to Dismiss for Lack of Jurisdiction filed March 3, 3022, the petition was filed prematurely with respect to petitioner's request for relief from joint and several liability. Petitioner filed an objection to respondent's motion, which was used to commence a new case at Docket No. 13124-22.
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). Thus, 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.