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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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Last modified: May 25, 2011