Opinion
21208-22S
01-09-2023
DIMAS LAMBERTY & DENISE LAMBERTY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On November 8, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice sufficient to confer jurisdiction upon the Court in this case was issued to petitioners. Petitioners filed a Notice of Objection to the motion on November 30, 2022.
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 Internal Revenue Service (IRS) correspondence received by petitioners disallowing their claim for Combat Related Special Compensation is not one of the types of IRS notices that gives rise to jurisdiction in this Court. Accordingly, and upon due consideration of the record of this case, it is
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction.