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