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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.
Discussion
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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