Service Employees International Union - Page 15

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          jurisdiction is based on the above-stated arguments, all of which           
          we find unpersuasive.  We agree with respondent that this Court             
          does not have jurisdiction over section 6652(c)(1) penalties for            
          purposes of section 6330(d)(1).  For this and all other reasons             
          stated herein, we shall grant respondent’s motions to dismiss for           
          lack of jurisdiction.                                                       
               We have considered all of petitioners’ arguments, and to the           
          extent they are not discussed herein, we conclude that they are             
          without merit or irrelevant.                                                
               To reflect the foregoing,                                              
                                                       Appropriate orders             
                                                  of dismissal for lack of            
                                                  jurisdiction will be                

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Last modified: May 25, 2011