- 7 - petition to indicate that respondent even determined a deficiency for 1995, much less that petitioners are disputing such deficiency. 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 petitioners' 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. Petitioners argue that they were not aware that the 1995 tax year was under examination and that respondent should have issued a single notice for 1993, 1994, and 1995.3 However, petitioners 3 We note, however, that the hearing record includes a copy of a letter dated Nov. 4, 1996, from the examining revenue agent stating, in part, that "the 1995 return will need to be examined and included with the 1993 and 1994 audit."Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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