Opinion
435-24L
04-12-2024
ARIANE J. MORGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On February 27, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that respondent had made no determination sufficient to confer jurisdiction on this Court as to petitioner's 2021 tax year. 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 §7442 does not provide this Court with jurisdiction to review all tax-related matters. As petitioner has not demonstrated that respondent made any 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 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.