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dischargeability of the tax deficiency in the bankruptcy
proceeding.
On December 19, 1996, respondent mailed a statutory notice
of deficiency to petitioner for his 1991 taxable year. The
deficiency apparently resulted from disallowances of certain
claimed deductions related to petitioner's businesses. On March
11, 1997, petitioner timely filed a petition to this Court.
The Tax Court is a court of limited jurisdiction, and its
powers may not exceed those conferred by statute. Sec. 7442;
Magazine v. Commissioner, 89 T.C. 321, 326 (1987); Burns, Stix
Friedman & Co. v. Commissioner, 57 T.C. 392, 396 (1971). This
Court lacks the requisite subject matter jurisdiction to decide
whether a taxpayer's deficiency was discharged in a bankruptcy
proceeding. Neilson v. Commissioner, 94 T.C. 1, 9 (1990).
As a general rule, this Court's jurisdiction to consider tax
matters depends on a notice of deficiency and a timely filed
petition. Secs. 6212 and 6213; Rule 13; Neilson v. Commissioner,
supra. The redetermination of an income tax deficiency has
"nothing to do with collection of the tax nor any similarity to
an action for collection of a debt, nor does it involve any other
rights and remedies of the sort traditionally enforced in an
action at law." Swanson v. Commissioner, 65 T.C. 1180, 1184
(1976). Accordingly, although we lack jurisdiction to determine
whether petitioner's deficiency had been discharged in
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