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Petrulis, D.D.S., S.C. v. Commissioner, 938 F.2d 78 (7th Cir.
1991). That adjudicatory power encompasses the redetermination
of deficiencies and the determination of overpayments. Secs.
6214(a), 6512(a). Moreover, we have jurisdiction only for
taxable years properly before us. Sec. 6214(b); see Hill v.
Commissioner, 95 T.C. 437 (1990).
Petitioners initiated the instant case in response to
respondent’s determination of deficiencies in the notices sent to
petitioners. Accordingly, we may decide the issue of whether the
February 12, 1999, remittances paid the deficiencies only if the
issue properly comes within our deficiency jurisdiction under
section 6214(a) or our overpayment jurisdiction under section
6512(a). We hold that this Court lacks jurisdiction to decide
the issue.
For purposes of section 6214, deficiencies are defined by
section 6211. Section 6211 defines a deficiency as follows:
SEC. 6211. DEFINITION OF A DEFICIENCY.
(a) In General.-–For purposes of this title in the
case of income, estate, and gift taxes imposed by
subtitles A and B and excise taxes imposed by chapters
41, 42, 43, and 44 the term “deficiency” means the
amount by which the tax imposed by subtitle A or B, or
chapter 41, 42, 43, or 44 exceeds the excess of–-
(1) the sum of
(A) the amount shown as the
tax by the taxpayer upon his
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