- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011