- 7 - The Court is a court of limited jurisdiction, and we may exercise our jurisdiction only to the extent authorized by Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The Court’s jurisdiction to review the Commissioner’s determinations respecting collection matters is limited to cases where the underlying tax liability is of a type over which the Court normally has jurisdiction. See Moore v. Commissioner, 114 T.C. 171 (2000). We lack jurisdiction under section 6330(d)(1)(A) to review respondent’s determination to collect the frivolous return penalty under section 6702 for 1997. Johnson v. Commissioner, 117 T.C. 204, 208 (2001) (dismissing petition for lack of jurisdiction where the Commissioner assessed only a frivolous return penalty under section 6702); Van Es v. Commissioner, 115 T.C. 324, 329 (2000) (“we do not * * * have jurisdiction to redetermine the frivolous return penalties assessed pursuant to section 6702”). Pursuant to section 6330(d), petitioner has 30 days after the entry of our order to file his appeal with the appropriate U.S. District Court for 1997. 2. No Decision on Whether Jeanie Henderson Is a Proper Party to This Action Respondent alleges that the notice for 1997 “was not required to be sent to petitioner-wife Jeanie Henderson since the liability was solely that of the petitioner-husband, Jason Henderson.” Petitioners filed an affidavit of record stating that Jeanie Henderson was an intended party to the action.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011