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by Congress. Estate of Branson v. Commissioner, 264 F.3d 904,
908 (9th Cir. 2001), affg. T.C. Memo. 1999-231. Section 6015(e)
provides that “In the case of an individual against whom a
deficiency has been asserted and who elects to have subsection
(b) or (c) apply * * * [he or she] may petition the Tax Court
(and the Tax Court shall have jurisdiction) to determine the
appropriate relief”. Sec. 6015(e)(1)(A) (emphasis added).
Because respondent did not assert a deficiency relating to either
1994 or 1996, this Court does not have jurisdiction to review
respondent’s determinations. Sec. 6015(e)(1); Billings v.
Commissioner, 127 T.C. ____ (2006).
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
An appropriate order of
dismissal for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011