United States Tax Court February 5, 2008, No. 5701-07L (Callahan v. Comm'r)

lead-opinion

OPINION

Haines, Judge:

This case is before the Court on respondent’s motion for summary judgment filed pursuant to Rule 121.1 The issues for decision are:

(1) Whether we have jurisdiction to review respondent’s determination issued under section 6330 when the underlying tax liability consists of frivolous return penalties.