Thompson v. Commissioner

WOLLMAN, Circuit Judge.

Randall and Karen Thompson appeal from an order of the United States Tax Court 1 that dismissed for lack of jurisdiction their petition challenging the Internal Revenue Service’s (IRS) assessment of a penalty with respect to their 2001 joint tax return. We affirm.

This, is the third appeal brought to challenge adjustments made by the IRS to 200Í tax returns filed by the Thompsons and a related partnership. See RJT Invs. X v. Comm’r, 491 F.3d 732 (8th Cir.2007) (partnership-level proceeding); Thompson v. Comm’r, 729 F.3d 869 (8th Cir.2013) (partner-level proceeding). We…