Opinion
8738-21
01-05-2023
PEDRO BECERRIL & PERLA BECERRIL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On July 12, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Although petitioners were directed to file an objection, if any, to the motion, no response was received.
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, upon due consideration of the record of this case and 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.