Diana Stroud, Petitioner, and Thomas M. Stroud, Intervenor - Page 4

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          by Congress.  Estate of Branson v. Commissioner, 264 F.3d 904,              
          908 (9th Cir. 2001), affg. T.C. Memo. 1999-231.  Section 6015(e)            
          provides that “In the case of an individual against whom a                  
          deficiency has been asserted and who elects to have subsection              
          (b) or (c) apply * * * [he or she] may petition the Tax Court               
          (and the Tax Court shall have jurisdiction) to determine the                
          appropriate relief”.  Sec. 6015(e)(1)(A) (emphasis added).                  
          Because respondent did not assert a deficiency relating to either           
          1994 or 1996, this Court does not have jurisdiction to review               
          respondent’s determinations.  Sec. 6015(e)(1); Billings v.                  
          Commissioner, 127 T.C. ____ (2006).                                         
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              


                                                  An appropriate order of             
                                             dismissal for lack of                    
                                             jurisdiction will be entered.            
















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