- 9 -
F.2d 750, 753 n.6 (10th Cir. 1992) (“lack of an OMB number on IRS
notices and forms does not violate” the PRA) (citing United
States v. Hicks, supra); Salberg v. United States, 969 F.2d 379,
384 (7th Cir. 1992); United States v. Kerwin, 945 F.2d 92 (5th
Cir. 1991); United States v. Wunder, 919 F.2d 34, 38 (6th Cir.
1990); Wheeler v. Commissioner, 127 T.C. 200, 208 (2006) (“The
Paperwork Reduction Act is not a defense to the addition to tax
under section 6651(a)(1), nor does it create a loophole in the
Code”); Aldrich v. Commissioner, T.C. Memo. 1993-290 (and cases
cited therein).
Citing dicta in the unpublished, nonprecedential opinion of
Pond v. Commissioner, 211 Fed. Appx. 749 (10th Cir. 2007), affg.
T.C. Memo. 2005-255, petitioner suggests that 1995 amendments to
the PRA call into question these well-established judicial
precedents. Petitioner has identified, however, and we have
discovered nothing in the 1995 amendments to the PRA to suggest
that they had this purpose or effect.4
3(...continued)
U.S. App. LEXIS 4237 (9th Cir. 1992), affg. T.C. Memo. 1990-304
and Warden v. Commissioner, T.C. Memo. 1990-321.
4 Although his contentions are vague, it appears that
petitioner may be alluding in part to 1995 amendments to 44
U.S.C. sec. 3512, which now provides in part: “Notwithstanding
any other provision of law, no person shall be subject to any
penalty for failing to comply with a collection of information
that is subject to this subchapter” if certain requirements of
(continued...)
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