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had been wrongfully deprived of $14 per hour by Edison and/or
Westinghouse. Petitioner, therefore, seeks a determination by
this Court regarding the dispute he has with Westinghouse and/or
Edison or urges this Court to order respondent to decide the
dispute. In order to obtain this remedy, petitioner refused to
file his 1990 return.
This Court is a court of limited jurisdiction, and that
jurisdiction is limited to redetermining the correct amount of a
deficiency. Secs. 7442, 6214; see also Utilicorp United, Inc. &
Subs. v. Commissioner, 104 T.C. 670, 674 (1995), and cases cited
therein. That jurisdiction does not extend to resolving disputes
between petitioner and other parties. Lewicki v. Commissioner,
T.C. Memo. 1974-86. With respect to the deficiency in this case,
petitioner concedes that he received the income determined by
respondent and that respondent's computation of the deficiency is
correct. Whatever the dispute between petitioner and
Westinghouse/Edison may be, we have no jurisdiction to decide the
matter, nor do we have the jurisdiction to order respondent to do
so.
While petitioner does not address respondent's determination
with respect to the addition to tax, section 6651(a)(1) provides
for an addition to tax for failure to timely file a return
"unless it is shown that such failure is due to reasonable cause
and not due to wilful neglect". Petitioner's alleged reason for
his failure to file his 1990 return was to cause respondent to
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