Opinion
14446-20
04-27-2022
RICHARDEEN BOWDEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
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). This Court's jurisdiction to redetermine a deficiency depends on the issuance of a valid notice of deficiency and a timely filed petition. Rule 13(a), (c), Tax Court Rules of Practice and Procedure; Monge v. Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988). Despite the fact that petitioner's late filing is due to an oversight, the Court has no authority to extend that statutory period. Axe v. Commissioner, 58 T.C. 256, 259 (1972). The petition in this case was not timely filed, and we are obliged to dismiss this case for lack of jurisdiction.
Upon due consideration, it is therefore
ORDERED that respondent's motion to dismiss is granted, and this case is dismissed for lack of jurisdiction.