- 6 -
Commissioner, 69 T.C. 75, 79-81 (1977), affd. 611 F.2d 1160 (5th
Cir. 1980); Bailey v. Commissioner, T.C. Memo. 1989-674, affd.
without published opinion 929 F.2d 700 (6th Cir. 1991).
In conclusion, we hold that for 1988 petitioner had
unreported net rental income of $445,352.
2. Unreported Income From Illegal Activities
In the notice of deficiency, respondent determined that
during the first 8 months of 1988, petitioner received $3,823,364
of “unreported funds by illegal means”. To arrive at this
figure, respondent first determined that petitioner’s alleged
illegal receipts for the month of August 1988 totaled
$477,920.50; respondent then projected petitioner’s alleged
5(...continued)
May 18, 1999); State v. Thrower, 621 N.E.2d 456, 457 (Ohio Ct.
App. 1993); State v. Thrower, No. 14967 (Ohio Ct. App. July 31,
1991); State v. Thrower, 610 N.E.2d 433, 434 (Ohio Ct. App.
1991); State v. Thrower, 575 N.E.2d 863, 876-877, 879 (Ohio Ct.
App. 1989).
Petitioner also seeks to assert in this action a breach of
contract “counterclaim” against respondent for “$250
million/specific performance as to property”. We lack authority
to address such a claim. The Tax Court is a court of limited
jurisdiction and may exercise only the power conferred by
statute. See sec. 7442; Neilson v. Commissioner, 94 T.C. 1, 9
(1990). Petitioner’s “counterclaim” falls outside that
jurisdiction.
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