- 2 -
This matter is before the Court on respondent’s motion to
dismiss for lack of jurisdiction as to income tax preparer
penalties assessed pursuant to section 6694. At the time of
the filing of the petition, petitioner resided in Georgetown,
South Carolina.
On September 9, 2004, respondent’s Appeals Office issued a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330, determining that a proposed lien was
appropriate with respect to income tax liabilities for
petitioner’s 1992, 1997, 1998, and 2000 tax years (tax notice).
The tax notice identified the liability in issue as follows:
Tax Period(s) Ended:
Form 1040, years 1992, 1997, 1998, 2000
The tax notice provided the following instructions for petitioner
to pursue a judicial review of the determination: If you want to
dispute this determination in court, you must file a petition
with the United States Tax Court for a redetermination within 30
days from the date of this letter.
Also on September 9, 2004, respondent’s Appeals Office
issued a second Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330, determining that a
proposed lien was appropriate with respect to petitioner’s 1992
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011