Julian B. Kraft - Page 4

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            of deficiency to petitioner; and (2) petitioner did not properly                          
            request an abatement of interest.                                                         
                  This matter was called for hearing at the Court's motions                           
            session in Washington, D.C.  Counsel for respondent appeared at                           
            the hearing and presented argument with respect to the pending                            
            motions.  Although petitioner did not appear at the hearing, he                           
            did a file a written statement with the Court pursuant to Rule                            
            50(c).                                                                                    
            Discussion                                                                                
                  The Tax Court is a court of limited jurisdiction, and we may                        
            exercise our jurisdiction only to the extent authorized by                                
            Congress.  Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  This                         
            Court's jurisdiction to redetermine a deficiency in tax depends                           
            upon the issuance of a valid notice of deficiency and a timely                            
            filed petition.  Rule 13(a), (c); Monge v. Commissioner, 93 T.C.                          
            22, 27 (1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147                             
            (1988).                                                                                   
            The Court's jurisdiction to redetermine a tax deficiency                                  
            generally does not extend to statutory interest imposed under                             
            section 6601.  See LTV Corp. v. Commissioner, 64 T.C. 589, 597                            
            (1975); see also Asciutto v. Commissioner, T.C. Memo. 1992-564,                           
            affd. 26 F.3d 108 (9th Cir. 1994).  One exception to the general                          
            rule stated above arises under section 7481(c) which confers                              
            jurisdiction on the Court to resolve disputes over respondent's                           





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