Ben D. And Patricia D. Stevens v. Commissioner of Internal Revenue

The Tax Court is given jurisdiction over cases in which a taxpayer timely petitions for redetermination of a deficiency determined by the Secretary of the Treasury and communicated to the taxpayer by a notice of deficiency. 26 U.S.C. § 6212 (1976). The issue is whether the Tax Court obtains jurisdiction when the taxpayers petition it for redetermination of a deficiency erroneously assessed on the basis that the taxpayer had failed to report a specific item of income. Here the taxpayers, having invoked the Tax Court’s jurisdiction, changed their minds before it decided the case and sought to…