- 19 - the Court has no jurisdiction over taxpayer’s compensatory claim that his credit rating was adversely affected by the filing of a lien); Chocallo v. Commissioner, T.C. Memo. 2004-152 (holding that the Court has no jurisdiction over taxpayer’s damages claim for alleged wrongs committed by respondent’s employees). If petitioners’ claim for monetary compensation were meant to be predicated on section 7432 and/or 7433, which provide for civil damages for failure to release a lien or certain unauthorized collection actions, respectively, we note that such claims must be brought in a District Court of the United States. D. Conclusion We have considered all of petitioners’ arguments, and, to the extent that we have not specifically addressed them, we conclude that they are without merit. Reviewed and adopted as the report of the Small Tax Case Division. To reflect our disposition of the disputed issues, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011