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Appeals officer conducted a hearing in petitioner’s case for tax
years 1987-89. On May 22, 2000, respondent sent petitioner a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330, in which respondent determined that the
jeopardy levy with respect to petitioner’s tax years 1987-89 was
appropriate.
OPINION
A. Background
Petitioner filed a petition seeking our review of
respondent’s determination that use of a jeopardy levy was
appropriate. The issue presented is whether our jurisdiction
under section 6330(d) to review section 6330 determinations
includes jurisdiction to review jeopardy levy determinations
under section 6330(f). We hold that it does.
The parties agreed that the Court had jurisdiction to review
respondent’s determination that the jeopardy levy was
appropriate. However, jurisdiction cannot be conferred upon the
Court by agreement, Neely v. Commissioner, 115 T.C. 287, 291
(2000); Naftel v. Commissioner, 85 T.C. 527, 530 (1985), and the
Court, sua sponte, can question jurisdiction at any time, Raymond
v. Commissioner, 119 T.C. 191, 193 (2002); Neely v. Commissioner,
supra at 290; Romann v. Commissioner, 111 T.C. 273, 280 (1998).
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