Opinion
919-24S
07-24-2024
CASEY T. CHERVENKA & JESSICA R. CHERVENKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On July 22, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction and To Strike as to Taxable Year 2024 (motion to dismiss) on the grounds that petitioners were not issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioners' 2024 tax year. Respondent represents that petitioners do not object to the granting of the motion to dismiss.
Like all federal courts, the Tax Court is a court of limited jurisdiction. Internal Revenue Code section 7442 does not provide this Court with jurisdiction to review all tax-related matters. As petitioners have not produced any notice of deficiency, nor demonstrated that respondent made any other determination that would permit petitioners to invoke the jurisdiction of this Court as to their 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 and To Strike as to Taxable Year 2024 is granted, in that it is, ORDERED 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.