Consequently, the " ‘[t]he only relevant inquiry in determining whether any court has [ ] subject matter jurisdiction is to ask whether the kind of claim which the plaintiff advances falls within the general scope of the authority conferred upon [the] court by the constitution or by statute.’ " Marion Cty. Auditor v. State, 33 N.E.3d 398, 400-01 (Ind. Tax Ct. 2015) (quoting Pivarnik v. N. Ind. Pub. Serv. Co., 636 N.E.2d 131, 137 (Ind. 1994) ). The Tax Court is a court of limited jurisdiction.

Consequently, the " ‘[t]he only relevant inquiry in determining whether any court has [ ] subject matter jurisdiction is to ask whether the kind of claim which the plaintiff advances falls within the general scope of the authority conferred upon [the] court by the constitution or by statute.’ " Marion Cty. Auditor v. State, 33 N.E.3d 398, 400-01 (Ind. Tax Ct. 2015) (quoting Pivarnik v. N. Ind. Pub. Serv. Co., 636 N.E.2d 131, 137 (Ind. 1994) ). The Tax Court is a court of limited jurisdiction.

Consequently, " ‘[t]he only relevant inquiry in determining whether any court has [ ] subject matter jurisdiction is to ask whether the kind of claim which the plaintiff advances falls within the general scope of the authority conferred upon [the] court by the constitution or by statute.’ " Marion Cty. Auditor v. State, 33 N.E.3d 398, 400-01 (Ind. Tax Ct. 2015) (citation omitted). The Tax Court, pursuant to its enabling legislation, has subject matter jurisdiction over all "original tax appeals."

The Department is mistaken. “Subject matter jurisdiction ‘refers only to the power of a court to hear and decide a particular class of cases.’ ” Marion Cnty. Auditor v. State, 33 N.E.3d 398, 400 (Ind.Tax Ct.2015) (quoting Pivarnik v. N. Ind. Pub. Serv. Co., 636 N.E.2d 131, 137 (Ind.1994) ). Subject matter jurisdiction does not depend upon the sufficiency or correctness of the averments in the petition, the stating of a good cause of action, or the validity of the petitioner's demand or right to relief. Id. (citing In re Adoption of H.S., 483 N.E.2d 777, 780 (Ind.Ct.App.1985) ). “Rather, ‘[t]he only relevant inquiry in determining whether any court has [ ] subject matter jurisdiction is to ask whether the kind of claim which the [petitioner] advances falls within the general scope of the authority conferred upon [the] court by the constitution or by statute.’ ”