Opinion
20005-23
04-30-2024
JENNIFER WIDENER LARSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On December 14, 2023, petitioner filed the Petition to commence this case, indicating therein that, with respect to tax years 2020 and 2021, she seeks review of a notice of deficiency, a notice of determination concerning relief from joint and several liability under section 6015 (or failure of IRS to make determination within 6 months after election or claim for relief), a notice of certification of a seriously delinquent federal tax debt to the Department of State, and a notice of determination under section 7623 concerning whistleblower action. No notice of deficiency or notice of determination is attached to the Petition.
On February 5, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction 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 the tax years at issue in this case. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, petitioner has not done so.
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 matters. 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 2020 and 2021 tax years, 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.