Opinion
4322-24
07-17-2024
MORRIS RUSSELL COE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On April 11, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of determination concerning collection action had been sent to petitioner, nor had respondent made any other determination with respect to a tax year that would confer jurisdiction on the Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.
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 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, the Court is obliged to dismiss this case for lack of jurisdiction.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted, and this case is dismissed for lack of jurisdiction.