David Soward - Page 7

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               IRC �� 162, 164, 165, 183, 212, or any other IRC                       
               section, they are not allowed as other deductions.                     
               On August 23, 2005, petitioner filed his petition in                   
          response to the notice of deficiency.  On May 30, 2006,                     
          respondent filed a motion to dismiss for lack of jurisdiction on            
          the ground that the statutory notice of deficiency was invalid              
          and prohibited by section 6225.  Respondent’s position is that              
          jurisdiction exists in either the District Court case or in                 
          docket No. 8753-05, but not both, and not in this case.                     
                                     Discussion                                       
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent provided by                    
          Congress.  See sec. 7442; see also GAF Corp. & Subs. v.                     
          Commissioner, 114 T.C. 519, 521 (2000).  We have jurisdiction to            
          redetermine a deficiency if a valid notice of deficiency is                 
          issued by the Commissioner and if a timely petition is filed by             
          the taxpayer.  GAF Corp. & Subs. v. Commissioner, supra at 521.             
          We have jurisdiction in this case only if the notice of                     
          deficiency sent to petitioner was valid.                                    
               The partnership-level procedures prescribed in sections 6221           
          through 6234 require that all challenges to adjustments of                  
          partnership items are to be made in a single unified proceeding.            
          Under these procedures, the tax treatment of any partnership item           
          shall be determined at the partnership level.  Sec. 6221.                   







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