- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011