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excessive without providing any statutory, regulatory, or case
precedent in support of his position. To the extent that
petitioner was entitled to question the amount of the penalties
and interest included in the outstanding 1991 tax liability, he
has not provided sufficient information from which we could
conclude that respondent’s assessed amounts are in error.
VI. Whether There Was Compliance by Respondent With
Sections 6631 and 6751
Sections 6631 and 6751, which were enacted as part of the
Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. 105-206, 112 Stat. 685, requires the Secretary to include
certain information on any notice to a taxpayer of liability for
interest or for a penalty. Sections 6631 and 6751 were effective
for notices sent to taxpayers after December 31, 2000, which date
was extended to June 30, 2001, by the Community Renewal Tax
Relief Act of 2000, Pub. L. 106-554, section 302(b) and (c), 114
Stat. 2763A-632. In addition, sections 302(b) and (c) of the
Community Renewal Tax Relief Act of 2000 also provided that the
requirements of sections 6631 and 6751(a) would be “treated as
met” if any notice issued after June 30, 2001, and before July 1,
9(...continued)
Although petitioner is not barred from contesting whether the
interest accumulated on the assessment was correctly computed by
respondent, he has not made that argument. See Urbano v.
Commissioner, 122 T.C. 384, 392-393 (2004). Petitioner’s
argument here is that accumulated interest on the addition to tax
and penalty causes those amounts to exceed the statutorily
prescribed percentages of 25 and 20 percent, respectively.
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