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determination to proceed with the collection of the taxes in
issue, and a timely filed petition. To the extent that Meyer v.
Commissioner, 115 T.C. 417 (2000), holds that we must first look
behind the determination to see whether a proper hearing was
offered in order to have jurisdiction, Meyer is overruled.
We are, of course, cognizant of the role stare decisis plays
in this Court and in other Federal courts, especially in the
context of statutory construction. See, e.g., Sec. State Bank v.
Commissioner, 111 T.C. 210, 213-214 (1998), affd. 214 F.3d 1254
(10th Cir. 2000). Nevertheless, when this Court decided Meyer v.
Commissioner, supra, lien and levy cases under section 6330 were
just starting to reach this Court. In the nascent stages of our
section 6330 jurisprudence, we made a decision limiting our
jurisdiction. After almost a year of experience in dealing with
lien and levy cases, we have come to the conclusion that the
jurisdictional analysis in Meyer was incorrect and has resulted
in unjustified delay in the resolution of cases. Whether there
was an appropriate hearing opportunity, or whether the hearing
was conducted properly, or whether the hearing was fair, or
whether it was held by an impartial Appeals officer, or whether
any of the other nonjurisdictional provisions of section 6330
were properly followed, will all be factors that we must take
into consideration under section 6330 in deciding such cases.
But none of these factors should preclude us from exercising our
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