- 3 - 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).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011