Opinion
4829-24S
08-20-2024
RAHKMAT ARITIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 28, 2024, petitioner filed the Petition to commence this case, indicating therein that petitioner seeks review of 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 July 16, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2024 (motion to dismiss) on the grounds that petitioner has not been issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2024 tax year. Although the Court provided an opportunity to petitioner to file an objection, if any, to the motion to dismiss, petitioner has not done so.
Like all federal courts, the Tax Court is a court of limited jurisdiction. As petitioner has not produced any notice of deficiency, nor demonstrated that respondent made any other determination that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2024 tax year, the Court is obliged to dismiss for lack of jurisdiction so much of this case relating to tax year 2024.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2024 is granted in that so much of this case relating to tax year 2024 is dismissed for lack of jurisdiction and deemed stricken from the Court's record.