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H. Respondent’s Motion To Dismiss
As stated, respondent filed a Motion to Dismiss for Lack of
Jurisdiction. Respondent contends that the Court lacks
jurisdiction on the grounds that: (1) The petition was not timely
filed with regard to the notice of deficiency dated February 9,
2000; and (2) respondent did not issue to petitioner a notice of
determination concerning collection actions under sections 6320
or 6330. Petitioner filed a notice of objection to respondent’s
motion.
Pursuant to notice, this matter was called for hearing at
the Court’s motions session in Washington, D.C. Counsel for
respondent appeared at the hearing and offered argument in
support of respondent’s motion to dismiss. Although there was no
appearance by or on behalf of petitioner at the hearing,
petitioner filed with the Court a written statement pursuant to
Rule 50(c).
After the hearing, the Court issued Orders directing
respondent to file supplements to his motion to dismiss.
Respondent complied with the Court’s Orders.
Discussion
The Tax Court is a court of limited jurisdiction. We may
exercise jurisdiction only to the extent expressly authorized by
statute. Breman v. Commissioner, 66 T.C. 61, 66 (1976).
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