Margaret M. Merker - Page 5

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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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