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not receive a notice of deficiency for the taxes in question or
did not otherwise have an earlier opportunity to dispute the tax
liability. Goza v. Commissioner, 114 T.C. 176, 180-181 (2000).
The term “underlying tax liability” includes additions to tax and
statutory interest that are the subject of the Commissioner’s
collection activities. Katz v. Commissioner, 115 T.C. 329, 339
(2000). To the extent that the underlying tax liability is at
issue, we review the taxpayer’s liability de novo. The Court
reviews other administrative determinations for an abuse of
discretion. Sego v. Commissioner, supra at 610.
1995 Taxable Year
We begin with the 1995 taxable year and respondent’s motion
to dismiss for mootness. Mootness is a jurisdictional question
since Article III, Section 2 of the Constitution limits the
jurisdiction of the Federal judicial system to “cases” and
“controversies”. Hefti v. Commissioner, 97 T.C. 180, 191 (1991),
affd. 983 F.2d 868 (8th Cir. 1993). Accordingly, “If a dispute
in litigation turns on the performance of a specific act, * * *
the litigation loses all substance and becomes moot when that act
is performed.” Id. at 191-192. Without a case or controversy,
this Court has no jurisdiction.
At the time of the issuance of the final notice on July 18,
2001, respondent’s account summary showed a balance due for 1995
of $368 plus statutory additions of $90.37. Thereafter,
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