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jurisdiction under section 6330(d), in order to resolve the
underlying dispute in a fair and expeditious manner.
In the instant case, there is nothing in the notice of
determination which leads us to conclude that the determination
was invalid. The notice of determination clearly embodies the
Appeals officer’s determination that collection by way of levy
may proceed. Thus, regardless of whether petitioners were given
an appropriate hearing opportunity, there was a valid
determination and a timely petition. Those are the only
statutory requirements for jurisdiction in section 6330(d)(1)(A).
Accordingly, we hold that we have jurisdiction to review the
determination in this case.
An appropriate order
will be issued.
Reviewed by the Court.
WELLS, COHEN, SWIFT, GERBER, COLVIN, GALE, and THORNTON,
JJ., agree with this majority opinion.
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