- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011