114 T.C. No. 11
UNITED STATES TAX COURT
JANET N. MOORE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16440-99L. Filed March 17, 2000.
P was an officer of a corporation that failed to
pay Federal trust fund taxes. R determined that P is
liable for a penalty pursuant to sec. 6672, I.R.C.,
equal to the unpaid taxes. After R initiated a
collection action against P, P received a due process
hearing with R's Boston Appeals Office. R issued a
determination letter to P stating that R would proceed
with collection. P filed a petition for review of R's
administrative determination with the Court. R filed a
motion to dismiss for lack of jurisdiction.
Held: The Court's jurisdiction to review an
administrative determination respecting a collection
matter is limited to cases where the underlying taxes
are of a type over which the Court normally has
deficiency jurisdiction. Secs. 6320(c), 6330(d),
I.R.C. Held, further, because the Court lacks
jurisdiction over the penalty that R is attempting to
collect, the Court lacks jurisdiction to review the
administrative determination in dispute.
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