Newby's Plastering, Inc. - Page 2

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          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.                                                                  
               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.                   
               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).  We             

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