Opinion
8655-24
08-30-2024
ENRIQUE MUNOZ & BERTA ALICIA MUNOZ Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
On July 19, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction (motion to dismiss) on the grounds that petitioners have not been issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioners' 2021 tax year. Petitioners have filed no objection to the granting of respondent's motion.
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 petitioners have not produced any notice of deficiency, nor demonstrated that respondent made any other determination, that would permit petitioners to invoke the jurisdiction of this Court as to their 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.