-3- 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.Page: Previous 1 2 3
Last modified: May 25, 2011