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This Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. See Savage v. Commissioner, 112 T.C. 46, 48 (1999);
Pen Coal Corp. v. Commissioner, 107 T.C. 249, 254 (1996); Kluger
v. Commissioner, 83 T.C. 309, 314 (1984). Our authorization
encompasses the determination of deficiencies pursuant to section
6214(a) and of overpayments, subject to specific limitations,
under section 6512(b). Obviously, the provisions of section
6512(b) are not applicable because petitioner herein has conceded
liability for the deficiency; he is not claiming any overpayment.
Accordingly, to demonstrate that this Court has jurisdiction,
petitioner must place this $20,400 remittance within the scope of
a deficiency.
Section 6211(a) defines the term “deficiency”. A deficiency
is the amount by which the tax imposed exceeds the excess of--
(1) the sum of
(A) the amount shown as the tax by the
taxpayer upon his return, if a return was made by
the taxpayer and an amount was shown as the tax by
the taxpayer thereon, plus
(B) the amounts previously assessed (or
collected without assessment) as a deficiency,
over--
(2) the amount of rebates, as defined in
subsection (b)(2), made. [Sec. 6211(a).]
Here, the $20,400 remitted by petitioner in 1984 was not
“shown as the tax” on the Federal income tax return he filed for
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