- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011