Kaye C. Schlachter - Page 4

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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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