Rosa Janus - Page 15

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          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           
          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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