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for 1989 through 1992.1 Respondent moves the Court to strike for
lack of jurisdiction the portion of the petition that seeks
relief under section 66(c) and to dismiss that portion of this
case accordingly. We shall grant that motion. On our own
initiative, we also for lack of jurisdiction shall strike the
portion of the petition that seeks relief under section 6013(e)
and dismiss that portion of the case.
On September 14, 2003, petitioner requested from respondent
relief under section 6015 as to each subject year. On
February 7, 2005, respondent informed petitioner that he was not
entitled to the requested relief. On April 20, 2005, petitioner
petitioned this Court to redetermine whether he was entitled to
any relief under section 6015, or under sections 66(c) and
6013(e). Petitioner resided in Irvine, California, when that
petition was filed.
This Court, like all Federal courts, is a court of limited
jurisdiction. See Flight Attendants Against UAL Offset v.
Commissioner, 165 F.3d 572, 578 (7th Cir. 1999); Estate of Wenner
v. Commissioner, 116 T.C. 284, 286 (2001). We acquire our
jurisdiction from Congress and may exercise jurisdiction over a
case only to the extent that Congress has authorized us to do so.
1 Section references are to the applicable versions of the
Internal Revenue Code. Sec. 6013(e) was repealed in 1998 by the
Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. 105-206, sec. 3201(a) and (e)(1), 112 Stat. 734, 740.
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