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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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