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