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Commissioner, 116 T.C. 255, 262 (2001) (holding that the
Commissioner may not waive the time restrictions imposed in
section 6330).
On the basis of the foregoing, we hold that we lack
jurisdiction inasmuch as the petition was not timely filed with
the Court. Accordingly, we shall grant respondent’s motion to
dismiss for lack of jurisdiction.
Petitioner also contends that the Appeals Office issued the
notice of determination without conducting an administrative
hearing. In Lunsford v. Commissioner, 117 T.C. 159, 164 (2001),
we recently held that we shall not look behind a notice of
determination to consider whether the Appeals Office conducted an
administrative hearing. Consistent with our holding in Lunsford
we hold that the notice of determination issued to petitioner is
valid.
We have considered petitioner’s remaining arguments and find
them to be meritless.
To reflect the foregoing,
An order of dismissal
for lack of jurisdiction
will be entered.
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