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taxable year. In that case, at docket No. 6313-95S, petitioners
argued that tier II railroad retirement benefits received by Mr.
Doxtator were exempt from Federal income tax because of
petitioners' status as Native Americans. We concluded, in an
unpublished Summary Opinion that has been made part of the record
in this case, that petitioners had failed to identify any statute
or treaty that would exempt the retirement benefits from tax and
accordingly sustained the deficiency. Our opinion was filed on
March 20, 1997.
OPINION
Jurisdiction
Petitioners contend that this Court does not have
jurisdiction over that portion of their deficiencies that relates
to "Treaty rights of the Oneida, income derived from The
Sovereign Government of the Oneida, and income from an investment
made by the Oneida Government, i.e. enrolled membership."
Petitioners concede our jurisdiction with respect to the issues
involving their claimed casualty loss and their investment
income. In context, as best we can understand petitioners'
claim, we believe they are challenging our jurisdiction to
redetermine the deficiencies determined with respect to Mrs.
Doxtator's compensation as a judicial officer for the Oneida
Tribe and their receipt of the $1,500 payments from the Oneida
Tribe.
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