- 5 - On September 5, 2006, respondent issued an affected items notice of deficiency to petitioners. The affected items notice was mailed after the 150-day period for filing a partnership proceeding had expired. Petitioners timely filed a petition in response to the affected items notice of deficiency. Discussion Respondent’s Motion To Dismiss 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. Id. We have jurisdiction in this case if petitioners did not previously pay any deficiencies. A. Remittance On August 30, 2005, petitioners remitted a check for $4,276,377. The written statement attached to the check indicated that petitioners were making a payment of tax and interest. Petitioners argue that they did not make a payment, but instead furnished a cash bond or in the alternative, made a deposit. Section 6603(a) provides:Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008