Jesse R. Lance - Page 8

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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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