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sufficient to render distributions to petitioner in the amounts
of $50,000 for 1984 and $17,500 for 1986 fully taxable as
dividends.
OPINION
Petitioner
Petitioner contends that respondent’s claims against him for
tax years 1984 and 1986 were discharged in bankruptcy. We first
address whether we have jurisdiction so to determine.5 As a
Court of limited statutory jurisdiction, see sec. 7442; Neilson
v. Commissioner, 94 T.C. 1, 9 (1990), our subject matter
jurisdiction is generally limited to the redetermination of the
correct amount of a deficiency determined by the Commissioner.
See sec. 6214(a); cf. Swanson v. Commissioner, 65 T.C. 1180, 1184
(1976) (an action commenced in this Court for redetermination of
a deficiency is unrelated to the collection of the tax). We lack
jurisdiction to determine whether a taxpayer’s liability for
Federal income taxes has been discharged in bankruptcy.
McAlister v. Commissioner, T.C. Memo. 1993-166 (citing Neilson v.
Commissioner, supra). Petitioner will have to invoke the
jurisdiction of the bankruptcy court to obtain a ruling on the
issue of discharge, if and when respondent attempts to collect
5 We always have jurisdiction to decide whether we have
jurisdiction. Sponza v. Commissioner, 844 F.2d 689, 690 (9th
Cir. 1988) (citing Weiss v. Commissioner, 88 T.C. 1036, 1040
(1987)).
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