- 6 - 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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