Opinion
6026-22
01-27-2023
KAREN ODOM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
The petition to commence this case was filed on March 7. On April 12, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the petition was not timely filed in response to the notice of deficiency upon which the case is based. Petitioner filed an objection to the motion by Letter received May 16, 2022.
The Tax Court is a court of limited jurisdiction, and we may exercise that jurisdiction only to the extent authorized by Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The Court has no authority to extend the deadline for filing a petition in response to a notice of deficiency, even given petitioner's health-related issues. See Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
Upon due consideration, and for the reasons set forth in respondent's motion, it is therefore
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction.