-3- 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 toPage: Previous 1 2 3 4 Next
Last modified: May 25, 2011