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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.
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). We
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