Opinion
2989-23
06-21-2023
YOKOV PILLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On April 21, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction (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 2017 through 2021 tax years. On May 8, 2023, an individual purporting to represent petitioner filed a Response to Motion to Dismiss for Lack of Jurisdiction. However, that individual is not admitted to this Court and therefore cannot represent petitioner before this Court. Accordingly, that response was stricken from the Court's record and the time was extended within which petitioner could file a response to the motion to dismiss. No response has been received from petitioner.
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 2017 through 2021 tax years, the Court is obliged to dismiss this case for lack of jurisdiction. However, although petitioner cannot prosecute this case in this Court, petitioner may still pursue an administrative resolution of petitioner's tax liabilities directly with the IRS.
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.