- 21 -
expired. Respondent contends we do not have jurisdiction under
section 6015(e) to review this issue.
We are a court of limited jurisdiction and may exercise our
power only to the extent authorized by Congress. Gati v.
Commissioner, 113 T.C. 132, 133 (1999); Naftel v. Commissioner,
85 T.C. 527, 529 (1985).
In her stand-alone petition, petitioner invoked our
jurisdiction under section 6015(e) to review respondent’s denial
of her request for relief from joint and several liability.
Section 6015(e)(1) limits our jurisdiction to reviewing
respondent’s denial of the specific relief contemplated under
section 6015. See Block v. Commissioner, 120 T.C. 62, 64-65
(2003); Ewing v. Commissioner, 118 T.C. at 499; Butler v.
Commissioner, 114 T.C. at 290. We do not have jurisdiction to
decide whether the period of limitation has expired because
petitioner’s request that we review the limitation issue goes
beyond the specific relief contemplated by section 6015. See
Block v. Commissioner, supra.6
To reflect the foregoing,
6Although our lack of jurisdiction precludes us from
deciding the limitation issue, we are satisfied the 10-year
period of limitation on petitioner’s 1989 tax liability, see sec.
6502(a)(1), has been substantially extended as a result of
petitioner’s and Mr. Ogonoski’s filing petitions for bankruptcy
in 1992 and 1993, see sec. 6503(h), and remains extended by the
pendency of this proceeding, see sec. 6015(e)(2).
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011