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administrative appeals available to the person.
In the Internal Revenue Service Restructuring and Reform Act
of 1998 (RRA 1998), Pub. L. 105-206, sec. 3401, 112 Stat. 746,
Congress enacted new section 6320 (pertaining to liens) and new
section 6330 (pertaining to levies) to provide protections for
taxpayers in tax collection matters. Section 6330 generally
provides that the Commissioner cannot proceed with enforced
collection by way of levy until the taxpayer has been given
notice of and the opportunity for an administrative review of the
matter (in the form of an Appeals Office hearing) and if
dissatisfied, with judicial review of the administrative
determination. See Davis v. Commissioner, 115 T.C. 35, 37
(2000); Goza v. Commissioner, 114 T.C. 176, 179 (2000).
When the Appeals Office issues a determination letter to a
taxpayer following an administrative hearing regarding a notice
of intent to levy, section 6330(d)(1) provides that the taxpayer
will have 30 days following the issuance of such determination
letter to file a petition for review with the Tax Court or, if
the Tax Court does not have jurisdiction over the underlying tax
liability, with a Federal District Court. See Offiler v.
Commissioner, 114 T.C. 492, 498 (2000). We have held that this
Court’s jurisdiction under sections 6320 and 6330 depends upon
the issuance of a valid determination letter and the filing of a
timely petition for review. See Moorhous v. Commissioner, 116
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