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claims that this is the "amount collected throughout the
years of the garnishment California placed on the wages".
In his trial memorandum, petitioner cites section 7214
relating to offenses by officers and employees of the
United States, as authority for his damage claim.
Furthermore, he asks the Court to allow him to deduct
$9,000 per year to reflect "the impact the events created
on his ability to earn income, both past, present and
future * * * in addition to any deductions that are
otherwise authorized."
The Tax Court has limited jurisdiction and may
exercise only the power conferred by statute. See sec.
7442; Neilson v. Commissioner, 94 T.C. 1, 9 (1990)
("This Court has limited jurisdiction conferred by
statute".). Petitioner's allegation that respondent's
conduct was improper in some way, such as amounting to a
violation of section 7214, is a matter over which this
Court has no jurisdiction. Cf. Boger v. Commissioner,
T.C. Memo. 1981-629. Petitioner has not shown that the
Court has jurisdiction to consider his claim for "damages"
under section 7214 or any other law.
Moreover, there is nothing in the record, and
petitioner has presented no evidence to substantiate his
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