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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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Last modified: May 25, 2011