Joseph W. Dorn - Page 3




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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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