- 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 1992Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011