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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
entered.
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Last modified: May 25, 2011