SEIU v. Comm'r
United States Tax Court
Ps are qualified labor organizations under I.R.C. sec. 501(c)(5) and are exempt from taxation under I.R.C. sec. 501(a). Ps did not timely file annual returns required by I.R.C. sec. 6033(a)(1). R assessed penalties against Ps under I.R.C. sec. 6652(c)(1) for failure to timely file those returns. Pursuant to I.R.C. sec. 6330(a), R issued notices of determination, attempting to collect the penalties by levy. Ps filed petitions contesting R's determination.
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Ps are qualified labor organizations under I.R.C. sec. 501(c)(5) and are exempt from taxation under I.R.C. sec. 501(a). Ps did not timely file annual returns required by I.R.C. sec. 6033(a)(1). R assessed penalties against Ps under I.R.C. sec. 6652(c)(1) for failure to timely file those returns. Pursuant to I.R.C. sec. 6330(a), R issued notices of determination, attempting to collect the penalties by levy. Ps filed petitions contesting R's determination. R filed motions to dismiss for lack of jurisdiction. Held: The Tax Court does not have jurisdiction over I.R.C. sec. 6652(c)(1) penalties…
1Opinion of the Court
SERVICE EMPLOYEES INTERNATIONAL UNION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent 100 OAK STREET CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
SEIU v. Comm'r
Nos. 8398-04L, 8399-04L
United States Tax Court
125 T.C. 63; 2005 U.S. Tax Ct. LEXIS 25; 125 T.C. No. 5;
September 15, 2005, Filed
Ps are qualified labor organizations under I.R.C. sec. 501(c)(5) and are exempt from taxation under I.R.C. sec. 501(a). Ps did
not timely file annual returns required by I.R.C. sec.
6033(a)(1). R assessed penalties against Ps under I.R.C. sec.
6652(c)(1) for failure to timely…
2Cases cited10 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Landry v. CommissionerUnited States Tax Court · 2001
- Moore v. CommissionerUnited States Tax Court · 2000
- Van Es v. CommissionerUnited States Tax Court · 2000
5 more not listed; retrieve them via the Exa API.