Williams v. Comm'r
United States Tax Court
P filed a petition timely seeking redetermination of deficiencies in income tax for 1993-2000 and attempting to put at issue certain liabilities for which he received no notice from R: P's income tax liability for 2001, his potential liability for unassessed interest on asserted tax liabilities, and his liability for a so-called FBAR penalty under 31 U.S.C. sec. 5321(a). R moved to dismiss in part, as to the three liabilities not included in the deficiency notice.
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P filed a petition timely seeking redetermination of deficiencies in income tax for 1993-2000 and attempting to put at issue certain liabilities for which he received no notice from R: P's income tax liability for 2001, his potential liability for unassessed interest on asserted tax liabilities, and his liability for a so-called FBAR penalty under 31 U.S.C. sec. 5321(a). R moved to dismiss in part, as to the three liabilities not included in the deficiency notice. Held: The Tax Court lacks jurisdiction to redetermine P's income tax liability for 2001, liability for unassessed interest, and…
1Opinion of the Court
OPINION
Gustafson, Judge:
This matter is before us on respondent’s “Motion To Dismiss for Lack of Jurisdiction and To Strike as to the Taxable Year 2001, as to Interest, and as to FBAR [foreign bank account report] Penalties” (the motion). Petitioner objects (the objection). We shall grant the motion.
Background
By notice of deficiency dated October 29, 2007, respondent determined deficiencies in petitioner’s 1993 through 2000 Federal income tax, along with penalties and additions to tax. By the petition, petitioner assigned error to those determinations. We have jurisdiction to consider…
2Cases cited11 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Hinck v. United StatesSupreme Court of the United States · 2007
- EC Term of Years Trust v. United StatesSupreme Court of the United States · 2007
- Breman v. CommissionerUnited States Tax Court · 1976
- Van Es v. CommissionerUnited States Tax Court · 2000
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