Patricia E. Ietto - Page 3

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            commission checks she received during 1991.  Petitioner                                       
            introduced copies of the checks into evidence.  The sum of these                              
            commission checks exceeded $15,813.                                                           
                  In the notice of deficiency, respondent determined that                                 
            petitioner underreported her 1991 commission income by $1,129,                                
            resulting in a deficiency in income tax of $172.  Respondent                                  
            further asserted that petitioner was liable for the employee's                                
            share of FICA taxes in the amount of $1,209 for 1991.  See sec.                               
            3101.                                                                                         
                  Petitioner filed the petition seeking a redetermination of                              
            these adjustments.  Respondent filed a motion to dismiss for lack                             
            of jurisdiction with respect to the employment taxes contained in                             
            the petition.                                                                                 
                                                OPINION                                                   
            FICA Taxes                                                                                    
                  The United States Tax Court is a court of limited                                       
            jurisdiction.  See sec. 7442; Wilt v. Commissioner, 60 T.C. 977,                              
            978 (1973).  Generally, this jurisdiction is limited to income,                               
            estate, gift, and certain excise taxes which are subject to the                               
            deficiency notice requirements of sections 6212(a) and 6213(a).                               
            Rule 13; Enochs v. Green, 270 F.2d 558 (5th Cir. 1959); Judd v.                               
            Commissioner, 74 T.C. 651, 653 (1980).  This Court has no                                     
            jurisdiction over FICA taxes imposed on an employee.  Chatterji                               
            v. Commissioner, 54 T.C. 1402, 1405 (1970).  Accordingly,                                     






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