- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011