- 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, 328-329Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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