Opinion
5399-24S
06-17-2024
JAMIE RECK-HILL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 14, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to and To Strike as to a Notice of Determination for the Taxable Year 2024 (motion to dismiss) on the grounds that petitioner was not issued any notice of determination, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2024 tax year. Respondent indicates that petitioner does not object to the granting of the motion to dismiss.
Like all federal courts, the Tax Court is a court of limited jurisdiction. As petitioner has not produced any notice of deficiency, nor demonstrated that respondent made any other determination that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2024 tax year, the Court is obliged to dismiss for lack of jurisdiction so much of this case relating to tax year 2024.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to and To Strike as to a Notice of Determination for the Taxable Year 2024 is granted in that so much of this case relating to petitioner's 2024 tax year is dismissed for lack of jurisdiction and deemed stricken from the Court's record.