Opinion
9065-24
07-11-2024
CONTINUED CARE NURSING SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On July 11, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction (motion to dismiss) on the grounds that petitioner was not issued any notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court as to petitioner's 2021 tax year. Respondent represents that petitioner does 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 issues. As petitioner has not produced any notice of deficiency, nor demonstrated that respondent made any other determination that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2021 tax year, the Court is obliged to dismiss this case for lack of jurisdiction.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.