James R. Ciciora - Page 5

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          deficiency reflected in the notice from $1,665 to $1,552, has               
          been corrected in the final calculation detailed above.                     
          Respondent now asserts that the initial $7,398 assessment should            
          be abated and seeks to have the amounts of income reflected in              
          the initial assessment included in the redetermination of                   
          petitioner’s deficiency.                                                    
               This Court is a court of limited jurisdiction, in that this            
          Court possesses only the adjudicatory powers that Congress has              
          conferred upon it.  Naftel v. Commissioner, 85 T.C. 527 (1985).             
          As is relevant to the present case, the adjudicatory power of               
          this Court encompasses the redetermination of deficiencies                  
          determined in statutory notices of deficiency.  Sec. 6214(a).  A            
          deficiency is defined generally as follows:                                 
                    SEC. 6211(a).  In General.--For purposes of this title            
               * * * the term “deficiency” means the amount by which the              
               tax imposed * * * exceeds * * * --                                     
                    (1) the sum of                                                    
                         (A) the amount shown as the tax by the taxpayer              
                    upon his return, if a return was made by the taxpayer             
                    and an amount was shown as the tax by the taxpayer                
                    thereon, plus                                                     
                         (B) the amounts previously assessed (or collected            
                    without assessment) as a deficiency * * *                         
          The amount of a deficiency is determined without regard to the              
          amount of taxes withheld on a taxpayer’s income.  Sec. 6211(a),             
          (b)(1).  However, the amount of withheld taxes and any other                








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