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to precede the noun “court” with the indefinite article “a”. The
use of the indefinite article, which does not fix the identity of
the noun modified, supports the conclusion that the flush
language of section 6330(d)(1) applies to both the Tax Court and
the district courts. See Webster’s II New Riverside University
Dictionary 621 (1994).
C. Section 6330(d)(1) Must Be Read in the Context of the
Statute
The section 6330(d)(1)(A) parenthetical language must be
read in the context of the statute. See Norfolk S. Corp. v.
Commissioner, 104 T.C. 13, 41 (1995). Section 6015(e)(1)
contains the same parenthetical language as section
6330(d)(1)(A); however, this same parenthetical language does not
provide the Court with unlimited jurisdiction over section 6015
cases. Our jurisdiction to review section 6015 cases is not
unlimited--in some cases the district court or United States
Court of Federal Claims has jurisdiction and the Tax Court does
not. Sec. 6015(e)(3)(C). Similarly, the language of section
6330(d)(1)(B) and the flush language limit and explain the
parenthetical language contained in section 6330(d)(1)(A).
D. District Courts Agree With Van Es and Moore
Several district courts have explicitly agreed with our
holdings in Moore and Van Es that our jurisdiction in lien and
levy cases is not unlimited. The United States District Court
for the Southern District of Texas held: “Courts have
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