- 37 - (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 ofPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011