Steven Michael Ryan - Page 3

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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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