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review the determination made by the Appeals officer. See sec.
301.6330-1(f)(1), Proced. & Admin. Regs.
A taxpayer who makes an untimely request for a section 6330
hearing is not entitled to a section 6330 hearing but will
instead receive an “equivalent hearing” under section
301.6330-1(i)(1), Proced. & Admin. Regs. An equivalent hearing
is held by the Appeals Office and generally is conducted in the
same manner as a section 6330 hearing. Sec. 301.6330-1(i)(1),
Proced. & Admin. Regs. However, the result of an equivalent
hearing is a decision letter, not a notice of determination. Id.
The decision letter generally contains the same information as a
notice of determination. Sec. 301.6330-1(i)(2), Q&A-I4, Proced.
& Admin. Regs. However, a decision letter issued by the Appeals
Office is not subject to judicial review under section 6330(d).
Id., Q&A-I5; see also Moorhous v. Commissioner, 116 T.C. 263,
270-271 (2001); Kennedy v. Commissioner, 116 T.C. 255, 263
(2001).
The Tax Court is a court of limited jurisdiction, and we may
exercise that jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
This Court’s jurisdiction under section 6330(d) is dependent upon
the issuance of a valid notice of determination by the Appeals
Office following the completion of a section 6330 hearing. See
Orum v. Commissioner, 123 T.C. 1 (2004), affd. 412 F.3d 819 (7th
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Last modified: November 10, 2007