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3. 1993, 1994, and 1995 Overpayments of Tax
Petitioner argues that no additions to tax are due for 1996
because she had overpayments of tax from 1993, 1994, and 1995 of
$2,694, $2,039, $1,902, respectively, that should be applied to
offset her 1996 underpayment as “estimated taxes for the
following years.” We are a Court of limited jurisdiction, and
one of the requirements for the Court to acquire jurisdiction is
that a statutory notice of deficiency be issued for the year that
petitioner seeks our review. Moretti v. Commissioner, 77 F.3d
637, 642 (2d Cir. 1996). No statutory notice of deficiency was
issued for any of the years for which petitioner seeks a
determination that there was an overpayment. Furthermore,
section 6214(b) provides that the
Tax Court in redetermining a deficiency of income tax * * *
shall consider such facts with relation to the taxes for
other years * * * as may be necessary correctly to
redetermine the amount of such deficiency, but in so doing
shall have no jurisdiction to determine whether or not the
tax for any other year * * * has been overpaid * * *.
Accordingly, we have no jurisdiction to review the validity
of these alleged overpayments. See Moretti v. Commissioner,
supra.
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