- 5 - Discussion I. Introduction Although in the petition and amended petition petitioner assigns numerous errors to respondent’s determinations and makes various averments in support thereof, on brief petitioner states the nature of the controversy between him and respondent to be the jurisdiction of the Court “on the points raised in Petitioner’s Motion to Dismiss.” He describes the issues to be decided as whether (1) “the Court has jurisdiction to decide this matter” (we assume respondent’s determinations), and (2) if we determine we do have jurisdiction, respondent has “lost the presumption of correctness.” He also claims that he is not liable for the remaining additions to tax. We shall address those issues. We deem petitioner to have abandoned any other errors he assigned. See Mendes v. Commissioner, 121 T.C. 308, 312-313 (2003) (“If an argument is not pursued on brief, we may conclude that it has been abandoned.”). II. Jurisdiction A. Introduction We have subject matter jurisdiction to redetermine a deficiency if the Commissioner has issued a valid notice of deficiency and the taxpayer has timely filed a petition. Secs. 6212 and 6213; Rules 13, 20; e.g., Monge v. Commissioner, 93 T.C. 22, 27 (1989). Because petitioner timely filed the petition,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007