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rejected his claim that his “income tax liability” for that year
was discharged in his bankruptcy case. Petitioner does not seek
relief as permitted under section 6330(c)(2)(A). He is thus
precluded from challenging that liability in this proceeding and
has, at the same time, failed to state a cognizable claim. See
Goza v. Commissioner, supra at 183.
Review of Statutory Interest
Petitioner makes an additional contention (separate from the
issues related to the tax deficiency and additions to tax) that
he is not liable for the statutory interest. He in effect argues
that we have jurisdiction to review the Appeals officer’s
determination with regard to the interest that is the subject of
respondent’s collection activities.
In Moore v. Commissioner, supra at 175, we interpreted
section 6330(d)(1)(A) and (B) as not expanding the Court’s
jurisdiction beyond the types of taxes that the Court may
normally consider (such as income, estate, and gift taxes). We
concluded that because we did not have jurisdiction to
redetermine Federal trust fund taxes determined by the
Commissioner under section 6672, we did not have jurisdiction to
review a determination made pursuant to section 6330 with regard
to those taxes. See id.
16(...continued)
Commissioner, 55 T.C. 879, 883-884 (1971); Krueger v.
Commissioner, 48 T.C. 824, 829-830 (1967); Hamdan v.
Commissioner, T.C. Memo. 2000-19.
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