Service Employees International Union - Page 7

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          Court has jurisdiction over many other aspects of petitioners’              
          tax status and should therefore have jurisdiction over the                  
          section 6652(c)(1) penalties assessed against them.  For purposes           
          of clarity and organization, we shall first address Tax Court               
          jurisdiction generally, followed by an analysis of petitioners’             
          three arguments.                                                            
          1.  The Tax Court Is a Court of Limited Jurisdiction                        
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent authorized by                  
          Congress.  Sec. 7442; Moore v. Commissioner, supra at 175; Naftel           
          v. Commissioner, 85 T.C. 527, 529 (1985).  The Tax Court                    
          generally has deficiency jurisdiction over income, gift, and                
          estate tax cases.  See secs. 6211(a), 6213(a), 6214(a); Downing             
          v. Commissioner, supra at 27; Van Es v. Commissioner, supra at              
          328.  For purposes of section 6330(d), the Court may have                   
          jurisdiction over an underlying liability for income, estate, or            
          gift tax even when no deficiency has been determined.  Montgomery           
          v. Commissioner, 122 T.C. 1, 7-8 (2004); Downing v. Commissioner,           
          supra at 27-28; Landry v. Commissioner, 116 T.C. 60, 62 (2001).             
          However, Congress did not intend to expand the Court’s                      
          jurisdiction under section 6330(d)(1) beyond the types of tax               
          over which we normally have jurisdiction.  See Van Es v.                    
          Commissioner, supra at 328-329; Moore v. Commissioner, supra at             

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