Donald Ertz - Page 37

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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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