-3-
section 7436(a) by its terms allows the Court to redetermine only
“the proper amount of employment tax” and not any additions
thereto. Petitioner argues alternatively that section 6651(a)(1)
by its terms does not allow the Court to redetermine an addition
to tax under that section in the case of a failure to file the
returns at issue; namely, Forms 941, Employer’s Quarterly Federal
Tax Returns. Petitioner asserts that Form 941 is an information
return that is required to be filed under authority of section
6041, notes that section 6041 is found in part III of subchapter
A of chapter 61 (part III), and notes that section 6651(a)(1)
provides explicitly that the addition to tax set forth therein
does not apply to a return required to be filed under authority
of part III.2
We reject both of petitioner’s arguments. Petitioner’s
challenge to our jurisdiction is a direct attack on our authority
to redetermine the additions to tax which we redetermined
adversely to petitioner in Charlotte’s Office Boutique, Inc. v.
Commissioner, supra. Our jurisdiction evolves from the Internal
Revenue Code, and we may exercise our jurisdiction only to the
extent authorized by Congress. Neilson v. Commissioner, 94 T.C.
1, 9 (1990); Naftel v. Commissioner, 85 T.C. 527, 529 (1985); see
also sec. 7442. Whether we have jurisdiction over the subject
2 Part III is entitled “Information Returns” and includes
secs. 6031 through 6060.
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