- 2 - have jurisdiction to decide whether petitioner is liable for these additions to tax. We hold we do not. Section references are to the Internal Revenue Code in effect for the year at issue. Rule references are to the Tax Court Rules of Practice and Procedure. Petitioner's principal place of business was in Anchorage, Alaska, when it petitioned the Court. Background Petitioner filed a 1989 Federal income tax return on May 18, 1993. On September 10, 1996, respondent issued petitioner a notice of deficiency reflecting a determination that petitioner was liable for the three additions to tax mentioned above. Respondent did not determine, and the notice of deficiency did not assert, that petitioner had a deficiency in its 1989 Federal income tax. Petitioner timely petitioned the Court with respect to the notice of deficiency, alleging in the petition that it was not liable for the additions to tax determined by respondent. The petition did not allege, and petitioner does not assert in this proceeding, that it overpaid its 1989 Federal income tax. Discussion This 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). WePage: Previous 1 2 3 4 Next
Last modified: May 25, 2011