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, 6230(a)(2)(A)(i), I.R.C. Anthony G. Tumminello, for petitioner. John J. Boyle, for respondent.Page: 1 2 3 4 5 6 NextLast modified: November 10, 2007