Susan Bocock and Jack Carl Ryals - Page 6

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          by respondent.  Petitioners refused to sign the decision document           
          prepared by respondent’s counsel.  The proposed decision document           
          stated that there was a deficiency in petitioners’ Federal income           
          tax of $18,481 and a section 6662(a) penalty of $1,848.                     
          Petitioners contend that respondent improperly credited to Mr.              
          Ryals’s 1978 tax liability one $7,000 payment and the two $2,000            
          payments and that those payments should have been applied to                
          petitioners’ 2002 taxable year.  Petitioners contend that the               
          decision document should reflect the payments as credits against            
          their 2002 tax liability.  On February 23, 2006, at the end of              
          the 30-day period, respondent filed the instant motion for entry            
          of a decision in accordance with respondent’s proposed decision             
          document.  On March 23, 2006, petitioners filed an objection to             
          respondent’s motion.  The motion was then set for hearing on                
          April 26, 2006.                                                             
                                       OPINION                                        
               We must decide whether we have jurisdiction to decide                  
          whether respondent improperly credited the payments in issue to             
          Mr. Ryals’s 1978 tax liability.  The Tax Court is a court of                
          limited jurisdiction and may exercise jurisdiction only to the              
          extent expressly authorized by Congress.  Naftel v. Commissioner,           
          85 T.C. 527 (1985).  Our deficiency jurisdiction encompasses the            
          redetermination of deficiencies under section 6214(a) and of                
          overpayments, subject to certain limitations, under section                 






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