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SMITH v. COMMISSIONER

Docket No. 9845-09.

133 T.C. 424 (2009)

SYDNEY G. AND LISA M. SMITH, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed December 21, 2009.

Attorney(s) appearing for the Case

Michael E. Lloyd and Stephen J. Pieklik , for petitioners.

John R. Bampfield , for respondent.

OPINION

KROUPA, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to the section 6707A penalties. We decide for the first time whether this Court has jurisdiction in a deficiency proceeding to redetermine a taxpayer's liability for section 6707A1 penalties. We conclude that we do not.

Background

We recite these facts solely for purposes...

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