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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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