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BEDROSIAN v. COMMISSIONER

Dkt. No. 24581-06.

94 T.C.M. 616 (2007)

T.C. Memo. 2007-376

John C. Bedrosian and Judith D. Bedrosian v. Commissioner.

United States Tax Court.

December 26, 2007.

Attorney(s) appearing for the Case

Richard E. Hodge, William E. Johnson, Steven R. Mather, and Elliott H. Kajan, for petitioners.

Michael L. Boman, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction.1 Respondent argues that the assessment of penalties relating to partnership adjustments is not subject to deficiency procedures, and that the deficiencies in income tax were paid and assessed prior to the issuance of the notice of deficiency. See generally Kligfeld Holdings v. Commissioner,

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