Mary K. Fisher and Charles F. Patterson, et al. - Page 15

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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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