- 15 - $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 overPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011