- 9 - with respect to that determination. Johnson v. Commissioner, 117 T.C. 204, 208-209 (2001). Thus, the remaining issue before the Court is whether this Court has jurisdiction to review the other determination in this case which relates to petitioner’s liability for income taxes and accuracy-related penalties. The Court recently held that, for purposes of determining the validity of a notice of determination for jurisdictional purposes, we shall not look behind a notice of determination to consider whether the Appeals Office conducted an appropriate hearing. Lunsford v. Commissioner, 117 T.C. 159 (2001). Our holding in Lunsford overrules Meyer v. Commissioner, 115 T.C. 417 (2001), to the extent it required the Court to look behind a notice of determination to discern whether a proper hearing opportunity was given in order to decide whether such a notice was valid. Lunsford v. Commissioner, supra at 164. In the instant case, this Court is not required to look behind the relevant notice of determination which relates to petitioner’s liability for income taxes and accuracy-related penalties in order to determine the validity of this notice. There is nothing in that notice of determination which leads us to conclude that the determination was invalid. As in Lunsford, the notice of determination clearly embodies the Appeals officer’s determination that collection by way of lien may proceed. Consistent with our holding in Lunsford, we hold thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011