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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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