Ginsberg v. Comm'r
United States Tax Court
P filed a complaint with District Court seeking review of R's determination to proceed with collection of a trust fund recovery penalty. The District Court remanded the case to R's Appeals Office, which issued a supplemental determination notice.
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P filed a complaint with District Court seeking review of R's determination to proceed with collection of a trust fund recovery penalty. The District Court remanded the case to R's Appeals Office, which issued a supplemental determination notice. The Pension Protection Act of 2006, amending sec. 6330(d), I.R.C. to expand this Court's jurisdiction over sec. 6330, I.R.C. determinations, became effective with respect to determinations made after a date that fell between the dates of the original determination notice and the supplemental determination notice. P filed a petition with this Court in…
1Opinion of the Court
OPINION
Kroupa, Judge:
This case is before the Court on respondent’s Motion to Dismiss for Lack'of Jurisdiction, filed October 5, 2007. Petitioner filed a petition to review respondent’s determinations in a supplemental determination notice that petitioner is liable for the trust fund recovery penalty for the periods ending June 30, 1991, December 31, 1991, September 30, 1992, March 31, 1994, and September 30, 1994 (the relevant periods). This issue arises because the supplemental determination notice was issued after the effective date of the amendment to section 6330(d)(1)1 and after…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Katz v. CommissionerUnited States Tax Court · 2000
- Moore v. CommissionerUnited States Tax Court · 2000
- Medeiros v. CommissionerUnited States Tax Court · 1981
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