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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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