- 19 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011