- 4 -
Therefore, even if petitioner did overpay his 1997 tax, a matter
as to which we express no opinion, we do not have jurisdiction to
determine any overpayment for that year. See Stewart v.
Commissioner, supra. Petitioner’s request to the Court to
determine an overpayment in tax for 1997 in order to redetermine
a deficiency in 1998 is expressly beyond the Court’s
jurisdiction.
An appropriate order will
be issued granting
respondent’s motion to dismiss
for lack of jurisdiction and
to strike the related portions
of the pleadings.
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Last modified: May 25, 2011