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Office hearing pursuant to section 6330(a)(2) and (3)(B) and (b).
Id.
II. Section 6702 Notice of Determination
The Court’s jurisdiction to review the Commissioner’s
determinations respecting collection matters is limited to cases
where the underlying tax liability is of a type over which the
Court normally has jurisdiction. See Moore v. Commissioner, 114
T.C. 171 (2000). We lack jurisdiction under section
6330(d)(1)(A) to review the Commissioner’s determinations
regarding the section 6702 frivolous return penalty. Johnson v.
Commissioner, 117 T.C. 204, 208 (2001); Van Es v. Commissioner,
115 T.C. 324, 329 (2000) (“we do not * * * have jurisdiction to
redetermine the frivolous return penalties assessed pursuant to
section 6702”).
Accordingly, we shall dismiss the petition as to the notice
of Federal tax lien regarding the section 6702 penalty for 1999
and 2000 on the ground that we lack jurisdiction to review
respondent’s determinations regarding the section 6702 penalty.
Johnson v. Commissioner, supra; Van Es v. Commissioner, supra.
Pursuant to section 6330(d), petitioner has 30 days after the
entry of our order to file his appeal with the appropriate U.S.
District Court regarding the notice of determination that
pertains to the notice of Federal tax lien for the section 6702
penalty for 1999 and 2000.
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Last modified: May 25, 2011