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Relief Act of 1997, Pub. L. 105-34, sec. 1238(a), 111 Stat. 1026.
However, the amendment to section 6221 is effective only for
partnership taxable years ending after August 5, 1997. See H.
Conf. Rept. 105-220, at 685 (1997) (effective for partnership
taxable years ending after the date of
enactment-–August 5, 1997).
Consistent with the preceding discussion, it follows that
the Court lacks jurisdiction to review the applicability of the
accuracy-related penalties for Hatchery's taxable years ending in
1994, 1995, and 1996. These penalties may only be contested at
the individual shareholder level following the completion of
Hatchery's corporate level proceeding. Accordingly, we shall
grant respondent's Motion to Dismiss for Lack of Jurisdiction and
to Strike insofar as respondent moves to dismiss and strike
allegations in the Hatchery petition pertaining to the accuracy-
related penalties.
In view of the foregoing,
Appropriate orders
will be issued.
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