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exercise our jurisdiction only to the extent authorized by
Congress.” Moore v. Commissioner, supra at 175. The Court’s
deficiency jurisdiction generally is limited to the
redetermination of income, estate, and gift taxes. See secs.
6211, 6213(a).
As noted above, the liabilities in issue were incurred with
respect to income tax preparer penalties assessed pursuant to
section 6694(a) and (b) for petitioner’s 1992 and 1993 tax years.
Section 6694(a) and (b) generally provide that an income tax
preparer may be subject to a penalty for preparation of a return
on which there is an understatement due to an unrealistic
position or due to willful or reckless conduct by the preparer.6
6SEC. 6694. Understatement of Taxpayer’s Liability by
Income Tax Return Preparer.
(a) Understatements Due to Unrealistic Positions.--If--
(1) any part of any understatement of liability with
respect to any return or claim for refund is due to a
position for which there was not a realistic possibility of
being sustained on its merits,
(2) any person who is an income tax return preparer
with respect to such return or claim knew (or reasonably
should have known) of such position, and
(3) such position was not disclosed as provided in
section 6662(d)(2)(B)(ii) or was frivolous,
such person shall pay a penalty of $250 with respect to such
return or claim unless it is shown that there is reasonable cause
for the understatement and such person acted in good faith.
(b) Willful or Reckless Conduct.--If any part of any
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