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of deficiency to petitioner; and (2) petitioner did not properly
request an abatement of interest.
This matter was called for hearing at the Court's motions
session in Washington, D.C. Counsel for respondent appeared at
the hearing and presented argument with respect to the pending
motions. Although petitioner did not appear at the hearing, he
did a file a written statement with the Court pursuant to Rule
50(c).
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). This
Court's jurisdiction to redetermine a deficiency in tax depends
upon 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, 90 T.C. 142, 147
(1988).
The Court's jurisdiction to redetermine a tax deficiency
generally does not extend to statutory interest imposed under
section 6601. See LTV Corp. v. Commissioner, 64 T.C. 589, 597
(1975); see also Asciutto v. Commissioner, T.C. Memo. 1992-564,
affd. 26 F.3d 108 (9th Cir. 1994). One exception to the general
rule stated above arises under section 7481(c) which confers
jurisdiction on the Court to resolve disputes over respondent's
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