- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011