- 14 -
Commissioner, supra (where we accepted such a concession without
deciding whether section 7491(c) applies in a section 6330
proceeding). On the record before us, we find respondent has met
the burden of production by coming forward with sufficient
evidence indicating that it is appropriate to impose on
petitioners those additions to tax. Petitioners bear the burden
of proving “reasonable cause” under section 6651(a). See Higbee
v. Commissioner, supra; Joye v. Commissioner, supra.
2. Jurisdiction in the Section 6330 Cases5
The Court has jurisdiction to review lien and levy
determinations under section 6330 if we generally have
jurisdiction over the underlying tax liability. Sec.
6330(d)(1)(A); Van Es v. Commissioner, 115 T.C. 324, 327 (2000);
Moore v. Commissioner, 114 T.C. 171, 175 (2000). The Court
generally has jurisdiction over income, gift, and estate tax
cases for purposes of section 6330(d)(1)(A) because the Court has
deficiency jurisdiction over such cases. See secs. 6211(a),
6213(a), 6214(a); Downing v. Commissioner, supra at 26-27; Landry
v. Commissioner, 116 T.C. 60, 62 (2001); Katz v. Commissioner,
115 T.C. 329, 339 (2000); Van Es v. Commissioner, supra at 328;
Goza v. Commissioner, supra at 182. Just as we have jurisdiction
5Neither party contends we lack jurisdiction. However, the
Court may consider sua sponte whether it has jurisdiction.
Moorhous v. Commissioner, 116 T.C. 263, 272 (2001); Neely v.
Commissioner, 115 T.C. 287, 290 (2000).
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