- 15 -
amount of $5,000. See Coulter v. Commissioner, 82 T.C. 580, 584-
586 (1984); Abrams v. Commissioner, 82 T.C. 403, 408-411 (1984).
In her trial memorandum and posttrial briefs, petitioner
makes two arguments that we address summarily. First, petitioner
contends that the "additions to tax under section 66017 [were]
not * * * claimed in the notices of deficiency for 1986 through
1991." We reviewed the notices and each did in fact make a
determination for interest under section 6601. Second,
petitioner's allegation that respondent in some way violated
section 72148 is a criminal matter over which this Court has no
jurisdiction. See Boger v. Commissioner, T.C. Memo. 1981-629;
Rice v. Commissioner, T.C. Memo. 1978-334.
Decisions will be entered
for respondent.
7 Sec. 6601 provides for interest on delinquent payments of
tax running from the last date prescribed for payment to the date
paid.
8 Sec. 7214 provides that any officer or employee of the U.S.
convicted of certain criminal acts in connection with any revenue
law of the U.S. may be dismissed from office or discharged from
his employment and fined not more than $10,000, or imprisoned not
more than 5 years, or both. It also provides for damages against
such officer or employee in favor of the party injured by such
officer's or employee's actions.
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