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Section 6696(b) provides that the deficiency procedures that
serve as a jurisdictional prerequisite for this Court do not
apply with respect to the assessment or collection of income tax
preparer penalties assessed pursuant to section 6694:
SEC. 6696(b). Deficiency Procedures Not to
Apply.--Subchapter B of chapter 63 (relating to
deficiency procedures for income, estate, gift, and
certain excise taxes) shall not apply with respect to
the assessment or collection of the penalties provided
by sections 6694 and 6695.
Because we lack jurisdiction with respect to the underlying
amounts in issue, we lack jurisdiction to review respondent’s
Appeals Office determination with respect to the collection of
those liabilities. Weber v. Commissioner, supra; Moore v.
Commissioner, supra; Van Es v. Commissioner, supra. Accordingly,
in the instant case, we conclude that this Court lacks
jurisdiction to review the determination of respondent’s Appeals
6(...continued)
understatement of liability with respect to any return or claim
for refund is due--
(1) to a willful attempt in any manner to understate
the liability for tax by a person who is an income tax
return preparer with respect to such return or claim, or
(2) to any reckless or intentional disregard of rules
or regulations by any such person,
such person shall pay a penalty of $1,000 with respect to such
return or claim. With respect to any return or claim, the amount
of the penalty payable by any person by reason of this subsection
shall be reduced by the amount of the penalty paid by such person
by reason of subsection (a).
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Last modified: May 25, 2011