Opinion
20239-23S
04-11-2024
KATHY E. DIXON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 9, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to and To Strike as to a Notice of Deficiency for the Taxable Year 2023 (motion to dismiss) on the grounds that petitioner was not issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2023 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. 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 as to petitioner's 2023 tax year, the Court is obliged to dismiss for lack of jurisdiction so much of this case relating to tax year 2023.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case relating to tax year 2023 is dismissed for lack of jurisdiction. Petitioner is advised that her claims with respect to the notice of deficiency issued for her 2021 tax year remain pending before the Court.