Opinion
23818-21
01-11-2023
CHATTANAT JAYANAMA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On November 16, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Although petitioner was directed to file an objection, if any, to the motion, no response was received.
The Tax Court is a court of limited jurisdiction, and we may exercise that jurisdiction only to the extent authorized by Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The Court has no authority to extend the deadline for filing a petition in response to a notice of deficiency. See Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022). Thus, upon due consideration of the record of this case and for the reasons set forth in respondent's motion, it is
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction.