- 4 - denied. The factual issue as to whether income charged to petitioner in respondent’s notice of deficiency represents income petitioner earned in his individual capacity or income earned as a partner in a TEFRA partnership does not go to the jurisdiction of this Court. In any event, because petitioner’s petition was filed late, we shall grant respondent’s motion to dismiss for lack of jurisdiction. In our discretion, we decline to award damages against petitioner under section 6673. To reflect the foregoing, An appropriate order of dismissal for lack of jurisdiction will be entered.Page: Previous 1 2 3 4Last modified: November 10, 2007