Jason and Jeanie Henderson - Page 7

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               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.                  



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