Gary R. Fears - Page 1
129 T.C. No. 2
UNITED STATES TAX COURT
GARY R. FEARS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21508-05. Filed August 2, 2007.
R determined, in a notice of final partnership
administrative adjustment, that P was liable for sec.
6662(a) and (h), I.R.C. penalties. R sent P a notice
of deficiency and assessed the penalties against P. P
filed a petition with this Court and asserted a
partner-level defense relating to the penalties. R
filed a motion to dismiss for lack of jurisdiction and
contended that the Court lacks jurisdiction to
determine whether P is liable for the penalties.
Held: This Court lacks jurisdiction to determine
whether P is liable for the penalties. Secs. 6221,
Anthony G. Tumminello, for petitioner.
John J. Boyle, for respondent.
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Last modified: November 10, 2007