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is asking this court to please, with due respect, to give her
some equitable relief.”
Discussion
The Tax Court is a court of limited jurisdiction and may
exercise only the power conferred by statute. E.g., Raymond v.
Commissioner, 119 T.C. 191, 193 (2002); Naftel v. Commissioner,
85 T.C. 527, 529 (1985); see also sec. 7442. It likewise is well
recognized, as a corollary to the foregoing principle, that the
Court generally lacks equitable powers to expand its statutorily
prescribed jurisdiction. E.g., Commissioner v. McCoy, 484 U.S.
3, 7 (1987); Bokum v. Commissioner, 992 F.2d 1136, 1140 (11th
Cir. 1993), affg. T.C. Memo. 1990-21; Woods v. Commissioner, 92
T.C. 776, 784-785 (1989). Moreover, the existence of
jurisdiction in a particular case is fundamental and may be
raised at any point in the proceeding, either by a party or by
the Court sua sponte. E.g., Smith v. Commissioner, 124 T.C. 36,
40 (2005); Raymond v. Commissioner, supra at 193; Naftel v.
Commissioner, supra at 530.
For the reasons set forth in Billings v. Commissioner,
supra, the Court has concluded that our jurisdiction under the
laws governing joint and several liability does not extend to
review of the Commissioner’s denials of requests for relief
pursuant to section 6015(f) where no deficiency has been
asserted. Nor can equitable or policy concerns expand this
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