John Maier III - Page 16

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          provision, vesting the Court with jurisdiction to review                    
          respondent’s administrative determination to grant Ms. Maier                
          relief from joint and several liability.                                    
               Petitioner contends that, absent review by the Court, he               
          will be left without a judicial remedy.  Whether petitioner truly           
          lacks a judicial remedy or not, it is well settled that the Court           
          may not rely on equitable considerations to expand its                      
          jurisdiction beyond the parameters established by Congress.  See            
          Commissioner v. McCoy, 484 U.S. 3, 7 (1987) (holding per curiam             
          that the Tax Court is "a court of limited jurisdiction and lacks            
          general equitable powers"); Healy v. Commissioner, 351 F.2d 602,            
          603 (9th Cir. 1965) (holding in the context of a late filing that           
          "no matter how allegedly inequitable the situation" the Tax Court           
          does not have the authority to excuse a taxpayer from                       
          jurisdiction requirements in the statute); Axe v. Commissioner,             
          58 T.C. 256, 259 (1972).  To the extent that petitioner believes            
          that he has suffered an injustice due to a flaw in the                      
          controlling statutory provisions, his recourse may be to seek a             
          legislative remedy.                                                         

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