Opinion
10525-24S
11-15-2024
TIMOTHY LORENZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 23, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Tax Years 2023 and 2024 (motion to dismiss) on the grounds that petitioner haswas not issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 20223 and 2024 tax years. Although the Court provided an opportunity to petitioner to file an objection, if any, to the motion to dismiss, petitioner has not done so.
Like all federal courts, the Tax Court is a court of limited jurisdiction. As petitioner has not produced any notice of deficiency, nor demonstrated that respondent made any other determination. that would permit petitioner to invoke the jurisdiction of this Court as to his 2023 and 2024 tax years, the Court is obliged to dismiss for lack of jurisdiction so much of this case relating to tax year 2023 and 2024.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Tax Years 2023 and 2024 is granted in that so much of this case relating to tax years 2023 and 2024 is dismissed for lack of jurisdiction and deemed stricken from the Court's record in this case. Petitioner is advised that so much of this case relating to the notice of deficiency issued for his 2021 tax year remains pending before the Court.