Opinion
7735-23S
06-23-2023
PEDRO BERNAL MATOM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 16, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2021 and To Strike (motion to dismiss) on the grounds that petitioner has not been issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2021 tax year. Respondent indicates that petitioner does not object to the granting of the motion to dismiss.
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 2021 tax year, the Court is obliged to dismiss so much of this case relating to tax year 2021.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2021 and To Strike is granted and so much of this case relating to tax yar 2021 is dismissed for lack of jurisdiction and deemed stricken from the Court's record.