Scott William Katz - Page 19




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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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