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$113,259. Petitioner's first argument is that we lack
jurisdiction to resolve this issue. Petitioner's argument in
this regard, as we understand it, is that the Court lacks
jurisdiction because petitioner's claim for an NOL carryover in
1991 did not affect his tax liability for that year. Petitioner
explains his position as follows: "Petitioner Patterson's net
operating loss carryforwards and, $0.59 plus tax, will buy
amedium coffee at MacDonalds. It is nothing. The Court does not
have jurisdiction over 'nothing'."
Petitioner's argument is without merit. Section 6213(a)
vests this Court, upon filing of a taxpayer's timely petition,
with jurisdiction over the adjustments contained in the notice of
deficiency and claims made in the petition. Petitioner claimed
an NOL carryover in the amount of $113,259 on his 1991 return.
Respondent, in the notice of deficiency, determined that
petitioner was not entitled to the claimed carryover.
Petitioner's petition in docket No. 6383-95 contests respondent's
determination insofar as it pertains to the disallowance of the
claimed NOL carryovers. Therefore, we have jurisdiction with
respect to this issue. Dorl v. Commissioner, 57 T.C. 720, 721
(1972), affd. per curiam 507 F.2d 406 (2d Cir. 1974)
Petitioner next contends that, notwithstanding the
jurisdictional issue, he is entitled to the NOL carryover claimed
on his return. An NOL is the excess of allowable deductions over
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