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,                    
               6230(a)(2)(A)(i), I.R.C.                                               

               Anthony G. Tumminello, for petitioner.                                 
               John J. Boyle, for respondent.                                         








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Last modified: November 10, 2007