Charles R. Cutler - Page 6




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          distributions were properly taxable to petitioner as determined             
          by respondent.                                                              
               Petitioner’s claim with respect to the denied patent                   
          application is not properly before this Court.  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, supra at 529.  We do not have jurisdiction to              
          consider claims related to a denied patent application.  As to              
          petitioner’s arguments with respect to the denial of his right to           
          vote, the Internal Revenue Code simply does not provide that an             
          inmate denied the right to vote is exempt from taxation.                    
               In the absence of any genuine dispute as to a material fact            
          in this case, we shall grant respondent’s motion for summary                
          judgment.                                                                   
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered.                     


















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