Opinion
17427-23
07-05-2024
PRADEEP KUMAR XPLORER PULAPPATTA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Lewis R. Carluzzo Chief Special Trial Judge
As noted in respondent's Motion to Dismiss for Lack of Jurisdiction, filed December 23, 2023, and now before the Court, it appears that petitioner is challenging a levy, although most of the petition, to the extent we understand the points petitioner attempts to make, consists of complaints beyond the Court's authority to address.
There are no attachments to the petition, the petition does not allege that respondent failed to act in any manner that could support the Court's jurisdiction over a claim for relief, and nothing else submitted by petitioner in this case could support the Court's jurisdiction to review the levy that petitioner appears to be challenging. All of this is consistent respondent's representation in the motion that a notice of determination as contemplated in I.R.C. section 6330 has not been issued to petitioner.
Premises considered, and for the reasons set forth in respondent's motion, it is
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction.