Wesley Sherwood - Page 11

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          Secretary to the individuals who sign notices of deficiency and             
          demand for payment; (3) copies of the verification from the                 
          Secretary that the requirements of any applicable law or                    
          administrative procedure have been met; and (4) copies of the               
          record of assessment from the office of the Secretary.                      
          Petitioner also asked Skidmore to identify any Internal Revenue             
          Code sections and regulations that create his tax liabilities.              
          Petitioner never spoke to Skidmore by telephone about the case.             
               On October 14, 2004, respondent determined that it was                 
          appropriate to file a lien with respect to petitioner’s unpaid              
          income taxes, penalties, and interest for 1997-2002 and that                
          petitioner must file a petition in this Court within 30 days if             
          he wanted to dispute the determination in the Tax Court.                    
                                       OPINION                                        
          A.   Penalties for Providing False Withholding Information and              
               for Filing a Frivolous Return                                          
               The Court can, sua sponte, question its jurisdiction.  Smith           
          v. Commissioner, 124 T.C. 36, 40 (2005); Urbano v. Commissioner,            
          122 T.C. 384, 389 (2004); Raymond v. Commissioner, 119 T.C. 191,            
          193 (2002).  This Court lacks jurisdiction to review the penalty            
          for providing false withholding information under section 6682,             
          Weber v. Commissioner, 122 T.C. 258, 264 (2004); Castillo v.                
          Commissioner, 84 T.C. 405, 411 (1985); and the frivolous return             
          penalty under section 6702, Johnson v. Commissioner, 117 T.C.               
          204, 209 (2001), Van Es v. Commissioner, 115 T.C. 324, 328-329              





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