Richard A. Wilson - Page 4




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                         Additions to Tax                                             
                    Year     Tax      Sec. 6651(f)     Sec. 6654                      
                    1991     ---   $71,834             $5,474                         
          1992     ---         36,197          2,105                                  
          1993     ---         54,570          3,049                                  
          1994     ---         63,185          4,372                                  

               On December 6, 2001, petitioner timely filed with the Court            
          a petition for redetermination, challenging the above-described             
          notice of deficiency.  At the time that the petition was filed,             
          petitioner resided in Holly, Michigan.                                      
               In response to the petition, respondent filed a Motion to              
          Dismiss for Lack of Jurisdiction on the ground that the notice of           
          deficiency is invalid because respondent did not determine any              
          “deficiency” within the meaning of sections 6211 and 6665.                  
          Petitioner filed an Objection to respondent’s motion to dismiss.            
          Thereafter, pursuant to notice, respondent’s motion was called              
          for hearing at the Court's motions session in Washington, D.C.2             
                                     Discussion                                       
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent authorized by                  
          statute.  Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  The             
          Court’s jurisdiction to redetermine a deficiency depends upon the           

          2  During the hearing, counsel for respondent argued that                   
          although the Court lacks jurisdiction to redetermine the                    
          additions to tax in question pursuant to its deficiency                     
          jurisdiction under sec. 6213(a), the Court may have the authority           
          to review such additions to tax pursuant to its collection review           
          jurisdiction under secs. 6320 and 6330.                                     





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