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(2000). However, River City Ranches #1 Ltd. v. Commissioner, 401
F.3d 1136 (9th Cir. 2005), affg. in part and revg. in part T.C.
Memo. 2003-150, indicates that our jurisdiction to determine
petitioner’s liability for section 6621(c) interest in this
partner-level proceeding may be limited.
A. Tax Court Jurisdiction Generally
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Sec. 7442; Moore v. Commissioner, 114 T.C. 171, 175
(2000); Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Although neither party has contested our jurisdiction,
jurisdiction may not be conferred upon the Court by agreement of
the parties. See Clark v. Commissioner, 125 T.C. 108, 109
(2005); Neely v. Commissioner, 115 T.C. 287, 291 (2000); Naftel
v. Commissioner, supra at 530. Whether the Court has
jurisdiction to decide an issue is a matter that this Court or a
Court of Appeals may decide at any time. Clark v. Commissioner,
supra at 109; Raymond v. Commissioner, 119 T.C. 191, 193 (2002).
B. Partnership Items Versus Affected Items and the Court’s
Jurisdiction To Determine the Character of a
Partnership’s Transactions
Congress enacted the partnership audit and litigation
procedures to provide a method to uniformly adjust items of
partnership income, loss, deduction, or credit that would affect
each partner. See Tax Equity and Fiscal Responsibility Act of
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