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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
175.
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