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