Marci L. and Carl C. Voigt - Page 4

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          jurisdictional motion.  On July 14, 2003, respondent filed a                
          motion for entry of decision.  By Order dated July 15, 2003, the            
          Court directed that petitioners could respond to respondent’s               
          motion on or before August 14, 2003.  The Court has received no             
          response from petitioners.                                                  
          A.  Jurisdiction                                                            
               The Tax Court is a court of limited jurisdiction; we may               
          exercise our jurisdiction only to the extent authorized by                  
          statute.  Sec. 7442; Commissioner v. Gooch Milling & Elevator               
          Co., 320 U.S. 418, 420 (1943).  By statute, this Court is                   
          authorized to redetermine the amount of a deficiency for a                  
          particular taxable period as to which the Commissioner issued a             
          notice of deficiency and the taxpayer petitioned the Court for              
          review.  See secs. 6212, 6213, and 6214.  This Court also has               
          jurisdiction to determine the amount of any overpayment a                   
          taxpayer might have made for a year that is properly before the             
          Court on a petition to redetermine a deficiency.  Sec.                      
          6512(b)(1).  If the Court determines that there is such                     
          overpayment, then the “amount of such overpayment * * * shall,              
          when the decision of the Tax Court has become final, be credited            
          or refunded to the taxpayer.”  Id.                                          
               Petitioners received a notice of deficiency with respect to            
          their 2000 tax year and duly petitioned this Court to redetermine           

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