Opinion
14791-23
01-18-2024
CLAYTON LANDON BARNET A.K.A. CLAYTON LANTON BARNET, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On October 24, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that (1) petitioner was not issued any notice of deficiency, nor has respondent made any other determination, as to petitioner's 2021 and 2022 tax years sufficient to confer jurisdiction on this Court, and (2) as to petitioner's 2021 tax year, this case is a duplicate of petitioner's case at Docket No. 19375-22, which was dismissed for lack of jurisdiction on December 14, 2022. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction, petitioner has not done so.
Like all federal courts, the Tax Court is a court of limited jurisdiction. Internal Revenue Code §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.