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See, e.g., Life Care Communities of America, Ltd. v.
Commissioner, T.C. Memo. 1997-95 (“It is now well settled that
the Tax Court lacks jurisdiction to consider whether a
taxpayer/partner is entitled to innocent spouse relief under
section 6013(e) in the context of partnership level
proceedings.”). Our jurisdiction under section 6226(f) is to
determine certain partnership items (and related allocation
questions), and, in exercising that jurisdiction, we must be
careful not to consider extraneous claims unrelated to that
limited jurisdiction.
C. Conclusion
Consistent with our limited jurisdiction under section
6226(f), we can consider petitioner’s claims of misconduct that
relate to respondent’s determination (or allocation) of
partnership items of the partnership. We shall examine how
respondent conducted himself with respect to the partnership, and
not how he conducted himself with respect to any other person,
except to the extent such person was acting for the partnership.
We shall address standing with more particularity as we proceed.
IV. Court’s Power and Authority
Having determined that the claims that we can consider are
limited by our subject matter jurisdiction, we must determine
whether we have the power and authority to provide the relief
requested by petitioner.
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