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Commissioner, 127 T.C. ____ (2006). After our Opinion was filed
in Billings, we issued an order directing the parties to show
cause why this case should not be dismissed for lack of
jurisdiction. Respondent filed a response to the Court’s order
agreeing that we lack jurisdiction. Petitioner filed a response
to the Court’s order objecting to the dismissal of this case.
The Tax Court is a court of limited jurisdiction, and we may
exercise that jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Whether this Court has jurisdiction is fundamental, and we may
question our jurisdiction at any time. Smith v. Commissioner,
124 T.C. 36, 40 (2005) (citing Raymond v. Commissioner, 119 T.C.
191, 193 (2002), Neely v. Commissioner, 115 T.C. 287, 290 (2000),
and Romann v. Commissioner, 111 T.C. 273, 280 (1998)); Naftel v.
Commissioner, supra at 530. As we have concluded that we do not
have jurisdiction to review the Commissioner’s denials of
requests for relief under section 6015(f) where no deficiency has
been asserted, we shall dismiss this case for lack of
jurisdiction.
To reflect the foregoing,
An order of dismissal for
lack of jurisdiction will be
entered.
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Last modified: May 25, 2011