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Petitioners’ argument must fail in this proceeding because our
jurisdiction is limited to deciding whether petitioners are
liable for the deficiency determined by respondent. This Court
is without jurisdiction to join unrelated third parties to an
individual taxpayer’s deficiency proceeding under the
circumstances of this case.6
Accordingly, we hold that petitioners are liable for the
$2,327.40 income tax deficiency for their 2001 tax year.7 To
reflect the foregoing,
Decision will be entered
for respondent.
6 We note that it is petitioners’ belief that the software
caused the error on their return. The record in this case does
not support or reject petitioners’ belief.
7 As discussed, we note that respondent has acknowledged
petitioners’ payment of $1,153.23 in response to respondent’s 30-
day letter. Accordingly, the amount of tax due from petitioners
will be less than the determined deficiency.
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Last modified: May 25, 2011