- 5 - OPINION Petitioner's brief does not directly address the taxability of the disability annuity but rather expresses petitioner's frustration and anger at the U.S. Government. Her various statements, requests, and arguments reflect these feelings. This Court is a court of limited jurisdiction. See sec. 7442; Wilt v. Commissioner, 60 T.C. 977, 978 (1973). Our jurisdiction to redetermine a deficiency is dependent on the issuance of a valid notice of deficiency. Sec. 6213(a); Rule 13(a); Estate of Bartels v. Commissioner, 106 T.C. 430, 435 (1996); Levitt v. Commissioner, 97 T.C. 437, 441 (1991). Our jurisdiction does not extend to settling employment disputes with various departments and agencies of the United States. See sec. 7442; Steines v. Commissioner, T.C. Memo. 1991-588, affd. without published opinion 12 F.3d 1101 (7th Cir. 1993). The issue over which we have jurisdiction is whether petitioner's FERS disability annuity payments, or any portion thereof, are excludable from gross income.4 Section 61(a) defines gross income broadly as "all income from whatever source derived". The Supreme Court "has given a liberal construction to this broad phraseology in recognition of 4 Petitioner's petition also sought to bring her 1994 taxable year before the Court. Since no notice of deficiency has been issued for petitioner's 1994 taxable year, we lack jurisdiction over petitioner's 1994 taxable year. Estate of Bartels v. Commissioner, 106 T.C. 430 (1996).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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