Opinion
26975-22
06-07-2023
MARTINEZ RAYSHON ANDERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On February 28, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that petitioner was not issued any notice of deficiency nor has respondent made any other determination sufficient to confer jurisdiction on this Court as to petitioner's 2021 and 2022 tax years. The Court issued an Order on March 31, 2023, directing petitioner to file an objection, if any, to respondent's motion. The copy of that Order served on petitioner was received by the Court as returned mail. Petitioner has not kept the Court informed of his current mailing address, as required by the Tax Court Rules of Practice and Procedure. Although petitioner was contacted by Court personnel and provided an opportunity to file a Notice of Change of Address, to date petitioner has failed to do so.
Like all federal courts, the Tax Court is a court of limited jurisdiction. Internal Revenue Code section 7442 does not provide this Court with jurisdiction to review all tax-related matters. As petitioner has not produced any notice of deficiency or demonstrated that respondent made any other determination that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2021 and 2022 tax years, the Court is 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.