Opinion
18919-22
03-21-2023
CARA S. EDMUND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On December 27, 2022, the Court issued an Order to Show Cause, directing the parties to show cause why so much of this case relating to tax years 2021 and 2022 should not be dismissed on the grounds that respondent has issued no notice of deficiency, nor has respondent made any other determination, as to petitioner's 2021 and 2022 tax years that would permit petitioner to invoke the jurisdiction of this Court. On January 17, 2023, respondent filed a Response to Order to Show Cause in which respondent states that he agrees that petitioner's 2021 and 2022 tax years should be dismissed on the grounds as stated by the Court. No response has been received from petitioner.
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 has made any other determination, that would permit petitioner to invoke the jurisdiction of this Court as to her 2021 and 2022 tax years, we are obliged to dismiss for lack of jurisdiction so much of this case relating to tax years 2021 and 2022.
Upon due consideration of the foregoing, it is
ORDERED that the Court's Order to Show Cause, issued December 27, 2022, is made absolute. It is further
ORDERED that so much of this case relating to petitioner's 2021 and 2022 tax years is dismissed for lack of jurisdiction and deemed stricken from the Court's record.