- 4 - erroneous August 31, 2000, taxable year contained in his answer was itself an error. Respondent suggests that the revenue agent who issued the original FPAA did so with the intent of making adjustments for Petaluma’s taxable year ending August 31, 2000. According to respondent, the revenue agent was confused by Petaluma’s 2001 return which was filed for a short taxable year ending August 31, 2001. Discussion Respondent moves to dismiss the petition for lack of jurisdiction. Respondent argues that because the July 28, 2005, notice makes adjustments for the wrong taxable year ending August 31, 2000, instead of the taxable year ending December 31, 2000, the FPAA is invalid, and the Court lacks jurisdiction to review the adjustments therein. Respondent argues that the only FPAA upon which the Court’s jurisdiction could have been invoked properly was the corrected FPAA issued on August 30, 2005. The Tax Court is a court of limited jurisdiction, and we may exercise our jurisdiction only to the extent provided by Congress. See sec. 7442; see also GAF Corp. & Subs. v. Commissioner, 114 T.C. 519, 521 (2000). This Court’s jurisdiction with respect to the tax treatment of partnerships is derived from the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648. Under the TEFRA provisions, the Commissioner must give notice to partnersPage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007