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and 1993 tax years (penalty notice). The penalty notice
identified the liability in issue as follows:
Tax Type/Form Number and Tax Period(s) Ended:
Civil Penalties, periods ended 12/31/1992, 12/31/1993
The record reveals that the penalties in issue include income tax
preparer penalties assessed, pursuant to section 6694(a) and (b),
for petitioner’s 1992 and 1993 tax years (the preparer
penalties). The penalty 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
have 30 days from the date of this letter to file a
complaint in the appropriate United States District
Court for a redetermination.
Petitioner timely filed a petition with this Court for
judicial review of the determination with respect to the preparer
penalties.1 On November 2, 2005, respondent filed the instant
motion to dismiss for lack of jurisdiction as to the preparer
penalties.
Section 6321 provides that if any person liable to pay any
tax neglects or refuses to pay the same after demand, the unpaid
tax shall be a lien in favor of the United States upon all
1Petitioner filed an amended petition on Oct. 19, 2004. We
note that petitioner has not challenged in this Court the
determination of respondent’s Appeals Office with respect to the
proposed lien related to the income tax liability for
petitioner’s 1992, 1997, 1998, and 2000 tax years, as set forth
in the tax notice.
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