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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).
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