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We have jurisdiction to redetermine the deficiency of any
taxpayer who is issued a valid notice of deficiency in respect of
any tax imposed by subtitle A of the Internal Revenue Code and
who timely files a petition for redetermination. Secs. 6212(a),
6213(a), and 6214(a); Monge v. Commissioner, 93 T.C. 22, 27
(1989); Normac, Inc. v. Commissioner, 90 T.C. 142, 147 (1988).
The record indicates that these jurisdictional requisites have
been satisfied.6 Petitioners have not suggested or shown any
defect in the notice of deficiency.
Nor have petitioners demonstrated any other basis on which
this Court lacks jurisdiction, notwithstanding their claim that
only Congress has the authority to consider certain of the issues
in this case. Native Americans such as petitioners are U.S.
citizens and generally are subject to Federal income tax in the
same manner as other U.S. citizens, absent specific exemption by
a treaty or statute. Squire v. Capoeman, 351 U.S. 1, 6 (1956);
Estate of Poletti v. Commissioner, 99 T.C. 554, 557-558 (1992),
affd. 34 F.3d 742 (9th Cir. 1994). While citing numerous
treaties and statutes, petitioners have pointed to no provision
that would affect our jurisdiction over the items they dispute.
To the contrary, as more fully discussed hereinafter, Mrs.
Doxtator's compensation for her services to the Oneida Tribe is
6 Respondent issued a notice of deficiency for the taxable
years 1997, 1999, and 2000 to petitioners on Oct. 31, 2002, and
petitioners timely filed a petition with this Court for
redetermination on Jan. 27, 2003.
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