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motion. Petitioner failed to file a response to respondent’s
supplement as directed by the Court.
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
The Court’s jurisdiction to review collection actions under
sections 6320 (liens) and 6330 (levies) depends on the issuance
of a notice of determination and the filing of a timely petition
for review. See Sarrell v. Commissioner, 117 T.C. 122, 125
(2001); Offiler v. Commissioner, 114 T.C. 492, 498 (2000).
Section 6330 generally provides that the Commissioner cannot
proceed with the collection of taxes by levy on a taxpayer's
property until the taxpayer has been given notice of and the
opportunity for an administrative review of the matter (in the
form of an Appeals Office hearing), and if dissatisfied, with
judicial review of the administrative determination in the Tax
Court or Federal District Court, as appropriate. Section 6330 is
effective with respect to collection actions initiated more than
180 days after July 22, 1998; i.e., January 19, 1999. See
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, sec. 3401(d), 112 Stat. 685, 750.
The record in this case shows that, in 1996, respondent
served notices of levy on the City of Philadelphia and Corestates
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