Opinion
11820-23
11-01-2023
HARJIT SINGH BHAMBRA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On September 21, 2023, respondent filed a Motion To Dismiss for Lack of Jurisdiction in the above-captioned matter at Docket No. 11820-23, bringing to the attention of the Court that the case is a duplicate of the proceeding at Docket No. 1395-16L, to the extent that both are premised on a notice of determination concerning collection action issued to petitioner with respect to taxable years 2003 and 2004. A decision was entered in Docket No. 1395-16L on March 27, 2019, and is now final pursuant to section 7481(a) of the Internal Revenue Code (I.R.C.).
Petitioner was served with a copy of respondent's motion and on October 30, 2023, filed an objection, with attachments. The objection centered on a refrain of fraud that petitioner has been bringing before this Court since at least the 2016 case. Attempting to initiate a new Tax Court case as to the notice of determination for 2003 and 2004 is simply not an appropriate vehicle for reprising any such complaints.
Accordingly, upon due consideration of the foregoing and the records in the cases at Docket Nos. 1395-16L and 11820-23, it appearing that the cases are duplicative, it is
ORDERED that respondent's just-referenced motion is granted, and the case at Docket No. 11820-23 is dismissed on the ground that the notice of determination for 2003 and 2004 does not provide a basis for petitioner to invoke the Court's jurisdiction in this action. See Abatti v. Commissioner, 859 F.2d 115, 117 (9th Cir. 1988), aff'g 86 T.C. 1319 (1986).