Opinion
10538-22
07-05-2022
RODNEY J. STOVER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On May 2, 2022, petitioner filed a petition to commence the instant case, attaching thereto a Letter 2644C issued in response to petitioner's inquiry to the Internal Revenue Service about two stimulus payments. A letter 2644C is not one of the types of notices that confer jurisdiction on upon the Court. On May 26, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice sufficient to confer jurisdiction upon the Court in this case was issued to petitioner. Petitioner filed an objection to the motion on June 21, 2022. No notice sufficient to confer jurisdiction upon the Court in this case was attached to the objection.
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). Accordingly, 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.