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treated as) motions to dismiss for lack of jurisdiction on the
ground that the determination letters are invalid.
Respondent subsequently supplemented his motions to dismiss,
as directed by the Court, by providing the Court with Postal
Service Form 3877 confirming that the Appeals Office mailed the
disputed determination letters to petitioners on January 13,
2000.
These cases were called for hearing at the Court's motions
session in Washington, D.C. Counsel for respondent appeared at
the hearing and argued in support of respondent's motions to
dismiss, as supplemented. Although petitioners did not appear at
the hearing, they did file Rule 50(c) statements 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
collection review procedures set forth in section 6330.3 Before
3 Sec. 6330 was enacted under the Internal Revenue Service
Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206,
sec. 3401, 112 Stat. 685, 746, and is effective with respect to
collection actions initiated more than 180 days after July 22,
1998; i.e., Jan. 19, 1999. See RRA 1998 Pub. L. 105-206, sec.
3401(d), 112 Stat. 750.
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