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his 1996 Federal income tax return, a form which is required for
reporting the receipt of IRA distributions.
In a notice of deficiency, respondent determined that all
the IRA distributions from Fidelity for the 1996 taxable year
were includable in gross income and therefore included an
additional $6,905 of 1996 IRA distributions from Fidelity in
petitioner’s 1996 gross income.
Tax Court Jurisdiction
First, petitioner contends that the order of Discharge of
Debtor which was entered in case No. 93-B-7643 on July 18, 1994,
is void ab initio because of fraud on the part of the bankruptcy
court. Therefore he asserts that the bankruptcy petition is
still pending and that the provisions of 11 U.S.C. section
362(a)(8) are applicable. Petitioner specifically alleges that
the judge in the bankruptcy proceedings received a bribe of at
least $6,700. Petitioner contends that any order issued by the
judge in case No. 93-B-7643 is therefore void for fraud.
This Court is a court of limited jurisdiction and may
exercise its jurisdiction only to the extent authorized by
Congress. See sec. 7442; Commissioner v. Gooch Milling &
Elevator Co., 320 U.S. 418, 420, 422 (1943); Naftel v.
Commissioner, 85 T.C. 527, 529 (1985). This includes Federal
income, estate, and gift taxes which are subject to the
deficiency notice requirements of sections 6212(a) and 6213(a).
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