- 5 - Respondent thereafter filed a motion to dismiss for lack of jurisdiction, to which petitioners filed an objection. Petitioners subsequently submitted a document to the Court that was filed as a motion to restrain assessment or collection. Therein, petitioners contend that certain levies issued with respect to petitioner Marc Ward were wrongful in light of the pendency of this case. Discussion Respondent maintains that we lack jurisdiction in this case because no notice of deficiency or notice of final determination not to abate interest with respect to taxable year 1994 or 1995 was issued to petitioners, nor was any other notice of determination sufficient to confer jurisdiction on this Court issued to them. The Tax Court is a court of limited jurisdiction, and we may exercise our jurisdiction only to the extent authorized by Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). It is undisputed that no notice of deficiency was ever issued to petitioners for 1994 or 1995. It is also undisputed that petitioners failed to request a hearing pursuant to section 6330(b) after they received a notice of intent to levy with respect to their tax liabilities for 1994 and 1995, and that no notice of determination concerning a collection action was issued to them concerning the levy. Consequently, we have noPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: March 27, 2008