- 11 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011