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of deficiency for 1993 and 1994 is attached to the Petition as an
exhibit. Finally, only the amounts of the deficiencies, addition
to tax, and penalties for 1993 and 1994 are identified in the
Petition as in dispute. Indeed, there is nothing within the four
corners of the Petition to indicate that respondent even
determined a deficiency for 1992.
In view of the foregoing, we hold that the Petition was
filed only in respect of the taxable years 1993 and 1994.
Accordingly, we analyze petitioner's motion for leave as one
seeking to amend the petition to place an additional taxable year
in issue. We therefore turn to the scope of this Court's
jurisdiction.
The Tax Court is a court of limited jurisdiction, and we
have only such jurisdiction as the Congress has chosen to confer
upon us by statute. Sec. 7442; Commissioner v. Gooch Milling &
Elevator Co., 320 U.S. 418, 420-422 (1943); Medeiros v.
Commissioner, 77 T.C. 1255, 1259 (1981). In a deficiency action,
our jurisdiction depends on the issuance of a valid notice of
deficiency and a timely filed petition. Rule 13(a), (c); Monge
v. Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v.
Commissioner, supra at 147.
Petitioner argues that respondent should have issued a
single notice for 1992, 1993, and 1994. However, petitioner
cites no rule of law, and we know of none, requiring respondent
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