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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 the
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