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costly, and administratively inconvenient" for them to file a
request for abatement of interest.
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Respondent's motion to dismiss and to strike concerns the Court's
jurisdiction over additions to tax and penalties on the one hand
and statutory interest on the other. For clarity, we address the
two matters separately.
1. Jurisdiction--Additions to Tax and Penalties
The Court's jurisdiction to redetermine a deficiency in tax
depends upon the issuance of a valid notice of deficiency and a
timely filed petition. Rule 13(a) and (c); Monge v.
Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v.
Commissioner, 90 T.C. 142, 147 (1988). Further, the Court's
jurisdiction generally is limited to a redetermination of the
deficiency determined in the notice of deficiency or an increased
deficiency, additional amounts, or additions to tax asserted by
the Commissioner at or before a hearing or rehearing. See secs.
6213(a), 6214(a).
Petitioners filed a timely petition contesting respondent's
deficiency determination, as well as additions to tax and
penalties for 1981. However, there is no dispute in this case
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