- 4 - 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'sPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011