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Petitioners are through their petition invoking the
jurisdiction that Congress provided to us in section 6330(d) as
made applicable by section 6320(c). Pursuant to section 6330(d),
we are empowered to redetermine the amount of an underlying tax
liability whenever that liability is properly at issue and is for
the type of tax that we normally consider in a deficiency
proceeding. Landry v. Commissioner, 116 T.C. 60, 62 (2001); see
also sec. 6330(c)(2)(B). Here, the type of “tax” at issue is
interest for which the parties, in part, dispute the
appropriateness of an abatement under section 6404(e).
The fact that we are not specifically authorized by section
6404(h) to redetermine interest, but are specifically empowered
only to decide the appropriateness of an abatement thereunder,
does not mean that we also lack jurisdiction under section
6330(d) to make such a redetermination in a lien proceeding such
as this. We have held that our jurisdiction under section
6330(d) allows us in a lien or levy proceeding to redetermine an
underlying tax liability that is entirely self-assessed, although
the liability is not a deficiency. Montgomery v. Commissioner,
122 T.C. 1 (2004); cf. sec. 6213(a). We do not read section 6330
as empowering us to decide only whether petitioners are entitled
to an abatement of interest, thus remitting them to a Federal
District Court lawsuit if they wish to challenge their interest
liability on another ground. Added expense would be borne by
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