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that the petition must be filed in 91 days. Petitioner refers in
its objection to the 92-day period first mentioned by respondent,
and, after pointing out that the 92d day fell on a Saturday,
notes that the petition was filed 2 days later on Monday. Even
if the petition were untimely, petitioner argues, respondent has
waived the right to challenge the timeliness of the petition, or,
alternatively, the Court should extend the period of time in
which the petition had to be filed. Petitioner alleges that
equitable considerations support a conclusion that the petition
was timely.
We agree with respondent that we do not have jurisdiction to
decide this case. We are a Court of limited jurisdiction, and we
may exercise our jurisdiction only to the extent authorized by
Congress. Neilson v. Commissioner, 94 T.C. 1, 9 (1990); Naftel
v. Commissioner, 85 T.C. 527, 529 (1985); see also sec. 7442.
Whether we have jurisdiction over the subject matter of a dispute
is an issue that either party thereto, or this or an appellate
court sua sponte, may raise at any time. The failure to question
our jurisdiction is not a waiver of the right to do so, for if we
lack jurisdiction over an issue, we do not have power to decide
it. See Insurance Corp. of Ireland, Ltd. v. Compagnie des
Bauxites de Guinee, 456 U.S. 694, 702 (1982); see also Brown v.
Commissioner, 78 T.C. 215, 217-218 (1982), and the cases cited
therein. As a Court of limited jurisdiction, we have no
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