William F. Urbano and Flota L. Urbano - Page 8

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          underlying the lien and sought an abatement of interest under               
          section 6404(a)(1) and (e)(1).  Appeals concluded that the                  
          interest underlying the lien was calculated correctly.  Appeals,            
          without giving any consideration to petitioners’ request for an             
          abatement of interest, also concluded that the interest as                  
          calculated was due and, accordingly, that the lien was proper.              
          Appeals noted in the notice of determination that petitioners               
          agreed with the revenue agent’s adjustments to their 1993 income            
          as originally reported, that these adjustments (exclusive of the            
          NOL carrybacks) resulted in a $130,926 deficiency for 1993, and             
          that the revenue agent had improperly applied the NOL carrybacks            
          in his calculation of statutory interest for 1993.  In connection           
          with the hearing, Appeals delivered to Bellavia a statement                 
          detailing respondent’s computation of the disputed interest and a           
          copy of section 6601(d)(1), the relevant statutory provision.               
               We start our analysis with a discussion of our jurisdiction            
          to decide this case.  Whether we have jurisdiction over the                 
          subject matter of a case is an issue that either party thereto,             
          or this or an appellate court sua sponte, may raise at any time.            
          The failure to question our jurisdiction is not a waiver of the             
          right to do so, for if we lack jurisdiction over an issue, we do            
          not have the power to decide it.  Ins. Corp. of Ireland, Ltd. v.            
          Compagnie des Bauxites de Guinee, 456 U.S. 694, 702 (1982); David           

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