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mean that we lack jurisdiction here. For purposes of section
6330(d), we may have jurisdiction over an underlying liability
for income, estate, or gift tax whether or not we have or had
deficiency jurisdiction in that case; the grant of jurisdiction
to the Tax Court to review lien and levy determinations relating
to such taxes is not limited to cases in which a notice of
deficiency was issued or in which there is a deficiency. Sec.
6330(d)(1)(A); Landry v. Commissioner, supra at 62. The taxpayer
in Landry opposed a levy on the grounds that he had paid the
amounts in issue with excess tax withholdings from earlier years.
However, even assuming that no notice of deficiency had been
issued, and that the Tax Court would have lacked deficiency
jurisdiction, we held that we had jurisdiction under section
6330(d)(1) because the underlying tax liability related to
Federal income taxes over which we have jurisdiction. Landry v.
Commissioner, supra.
We conclude that, for purposes of section 6330(d)(1), we
generally have jurisdiction over the addition to tax under
section 6651(a)(2). Thus, we conclude that we have jurisdiction
to review respondent’s determination under section 6330 that
reasonable cause does not exist to excuse petitioners from
liability for the addition to tax under section 6651(a)(2) for
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