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and exercise equitable powers within its own
jurisdictional competence. * * * [Quotation marks
omitted.]
The Court of Appeals for the Seventh Circuit stated similarly in
Flight Attendants Against UAL Offset v. Commissioner, 165 F.3d
572, 578 (7th Cir. 1999). There, the Court of Appeals for the
Seventh Circuit, while suggesting but not deciding that this
Court has the power to apply the equitable doctrines of tolling
and estoppel, stated that the “the predecessor bodies to the Tax
Court, such as the Board of Tax Appeals, were administrative
agencies having more limited powers than a regular court * * *
[b]ut the present Tax Court operates pretty indistinguishably
from a federal district court.” Accord Buchine v. Commissioner,
20 F.3d 173, 176 (5th Cir. 1994) (Court of Appeals for the Fifth
Circuit concluded that this Court is empowered to apply the
equitable principle of reformation to a case over which it
already had jurisdiction), affg. T.C. Memo. 1992-36.
G. Ability of This Court To Apply the Principles of
Rule 60(b)
Here, no one disputes that we had jurisdiction to
redetermine the estate tax deficiency that was at issue. If one
of the parties in this case were now to make a motion subject to
the principles of rule 60(b), the issue as I see it would be
whether we would have authority to give effect to a purported
5(...continued)
v. Commissioner, 501 U.S. 868 (1991), 4 years later.
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