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Because we do not have jurisdiction over the assessment of the
section 6702 frivolous return penalties, we also dismiss for lack
of jurisdiction the part of the petition challenging the
collection of the outstanding amounts listed in the levy notice
for the frivolous return penalties and related interest.3
Pursuant to section 6330(d), petitioner has 30 days after the
entry of our order of dismissal to file his appeal with the
appropriate U.S. District Court.
To reflect the foregoing,
An appropriate order of
dismissal will be entered.
3 Petitioner does not make an argument that he is not
liable for the interest. Cf. Katz v. Commissioner, 115 T.C. ___,
___ (2000) (slip op. at 7-8, 19). We therefore interpret
petitioner’s challenge to respondent’s collection activities as
being based solely on petitioner’s view that the section 6702
frivolous return penalties were illegally assessed.
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