A corporation was not allowed to petition against the IRS in Tax Court because it had been suspended by the California Secretary of State. The most common reasons for suspension are failure to file/pay income tax OR failure to timely file the annual Statement of Information. You can check your corporation’s status with the Sec of State online at www.sos.ca.gov.
Ref: Timbron International Corp V. Commissioner, TC Memo 2019-31
It’s important to keep your corporation current.