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As indicated, respondent filed Motions to Dismiss for Lack
of Jurisdiction and to Strike the allegations in the petitions
relating to shareholder basis and the accuracy-related penalty.2
Petitioners filed objections to respondent's motions.
These cases were called for hearing at the Court's motions
session in Washington, D.C. Counsel for both parties appeared at
the hearing and offered argument in support of their respective
positions. Following the hearing, both parties filed memoranda
with the Court.
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. See sec. 7442; Judge v. Commissioner, 88 T.C. 1175,
1180-1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529
(1985).
These cases are before the Court pursuant to the unified
subchapter S corporation audit and litigation procedures set
forth in subchapter D of chapter 63 of subtitle F.3 The
2 Insofar as the paragraphs of the petitions described
above are concerned, we regard respondent as moving to strike
paragraphs 6(i) and (j) of both the Hatchery and Foods petitions,
as well as paragraphs 6(k), (l), and (m) of the Hatchery
petition.
3 Subchapter D of chapter 63 of subtitle F, consisting of
secs. 6241-6245, was codified pursuant to the Subchapter S
Revision Act of 1982, Pub. L. 97-354, sec. 4(a), 96 Stat. 1691-
1692. This subchapter was repealed applicable to tax years
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