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gift, and certain excise taxes), subsection (a) shall
not apply to any addition to tax under section 6651,
6654, or 6655; except that it shall apply--
(1) in the case of an addition
described in section 6651, to that portion of
such addition which is attributable to a
deficiency in tax described in section 6211;
or
(2) to an addition described in section
6654 or 6655, if no return is filed for the
taxable year.
Because respondent has not determined a deficiency in tax,
we hold that we lack jurisdiction to decide this case. To
reflect the foregoing,
An appropriate order
of dismissal for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011