Linda M. Weiler, a.k.a. Linda M. Krupnick - Page 10

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            that Mr. Weiler is not relieved from liability for penalties and                            
            interest attributable or allocable to the $4,841 adjustment                                 
            because it resulted from the disallowance of his expenses.  Sec.                            
            6015(b), (c), and (d); Hopkins v. Commissioner, supra.                                      
            C.    Underlying Liability for the Penalty and Interest Abatement                           
                  In the stipulation of facts, Mr. Weiler conceded the                                  
            adjustments determined in the notice of deficiency.  Therefore,                             
            we do not construe his request that the penalty be waived to be a                           
            challenge to the merits of his underlying liability for the                                 
            penalty.  Accordingly, this is not in issue.                                                
                  Mr. Weiler’s contention that the interest attributable to                             
            the $4,841 adjustment should be abated is broad enough to be                                
            considered a request for interest abatement pursuant to section                             
            6404.  The concession in the stipulation of facts regarding the                             
            adjustments determined in the notice of deficiency can be read as                           
            not including the issue of interest abatement.  For the sake of                             
            completeness, we shall address this issue.                                                  
                  The Tax Court is a court of limited jurisdiction and may                              
            exercise jurisdiction only to the extent authorized by Congress.                            
            Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  The question of                           




                  7(...continued)                                                                       
            in sec. 6015(d)(3)(B) does not apply because Mr. Weiler had                                 
            sufficient income to offset the disallowed deduction.  See                                  
            Hopkins v. Commissioner, 121 T.C. ___ (2003)                                                





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