- 11 - Section 6213(a) provides that this Court may enjoin respondent's collection efforts if respondent is attempting to collect amounts that have been placed in dispute in a timely filed petition for redetermination. See Powell v. Commissioner, 96 T.C. 707, 711 (1991). However, this Court does not have jurisdiction in an affected items deficiency proceeding to restrain assessment and collection of computational adjustments attributable to partnership items. See id. The amounts listed as due in the notice of intent to levy represent the balance due from petitioners for the deficiencies that were assessed by computational adjustment and section 6621(c) additional interest. Having decided that we lack jurisdiction to redetermine these items, we must deny petitioners' motion to restrain assessment and collection. An appropriate order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011