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distribution in 1992; petitioner received that distribution
regardless of whether he held a lease on the 270 acres.9
Petitioner's argument is wholly without merit.
The Court recognizes the possibility that petitioner may
have incurred some pecuniary damages as a result of his inability
to farm the leased land during the year at issue. Moreover, the
Court understands that petitioner may harbor feelings of
inequitable treatment surrounding his relinquishment of what he
regarded as tax-free farming income and the subsequent receipt by
him of a taxable per capita distribution from the casino
operations. Although the Court may sympathize with petitioner's
quandary, this Court is a court of limited jurisdiction and lacks
general equitable powers. Commissioner v. McCoy, 484 U.S. 3, 7
(1987); Hays Corp. v. Commissioner, 40 T.C. 436 (1963), affd. 331
F.2d 422 (7th Cir. 1964); see sec. 7442. The Court has no
authority to disregard the express provisions of statutes adopted
by Congress, even where the result in a particular case may seem
harsh. See, e.g., Estate of Cowser v. Commissioner, 736 F.2d
9
It is notable that petitioner did not produce any evidence
to show that his lease was still valid in 1992 (i.e., had not
been validly terminated by the tribal council in 1991). This may
be one of the issues to be resolved in the arbitration of
petitioner's dispute with the tribal council. The validity of
the lease is made moot by this Court's determination that the
existence of the lease has no bearing on the taxability of the
subject per capita distribution. Nevertheless, petitioner failed
to prove on this record that the lease was valid during the year
at issue. On this record, it appears that the tribal council
terminated the lease pursuant to the terms of the lease.
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