- 5 - 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 This subchapter was repealed applicable to tax years (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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