Opinion
4829-24S
07-03-2024
RAHKMAT ARITIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On March 28, 2024, petitioner Rahkmat Aritin filed the Petition to commence this case, indicating therein that petitioner seeks review with respect to a notice of deficiency issued for petitioner's 2024 tax year. However, the notice of deficiency filed as an Attachment to Petition was issued for petitioner's 2021 tax year. On April 26, 2024, respondent filed an Answer to the Petition. Therein, respondent denies that this case is based on a notice of deficiency issued for petitioner's 2024 tax year and alleges that only a notice of deficiency issued for petitioner's 2021 tax year is properly at issue. On July 2, 2024, the parties filed a Proposed Stipulated Decision that addresses only petitioner's 2021 tax year.
Like all federal courts, the Tax Court is a court of limited jurisdiction. This Court's jurisdiction in a deficiency case depends, in part, on respondent's issuance of a valid notice of deficiency for the tax year(s) in dispute. See Internal Revenue Code § 6213(a). Here, petitioner has not produced or otherwise demonstrated that respondent issued any notice of deficiency, or made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2024 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 26, 2024, respondent shall file an appropriate jurisdictional motion with respect to so much of this case relating to petitioner's 2024 tax year. We will hold the parties' Proposed Stipulated Decision pending further action by the Court.