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We need not solve the puzzle of section 6331(i)(3)(B)(i),
however, because we agree with respondent that we cannot grant
petitioners the relief they request in any event.
B. Lack of Jurisdiction
As the Supreme Court observed in Owen Equip. & Erection Co.
v. Kroger, 437 U.S. 365, 374 (1978): “It is a fundamental
precept that federal courts are courts of limited jurisdiction.
The limits upon federal jurisdiction, whether imposed by the
Constitution or by Congress, must be neither disregarded nor
evaded.” We have only the authority given to us by Congress.
Sec. 7442; e.g., Bernal v. Commissioner, 120 T.C. 102, 107
(2003). Petitioners invoke our authority under section 6330(d)
to review a determination made pursuant to that section to
proceed with a collection action (a section 6330 determination)
and, under certain circumstances, to enjoin that action. They
pray that we compel respondent to return the overpayment to them.
With respect to the content of the petition in an action
brought under section 6330(d), Rule 331(b) provides that a copy
of the notice of determination accompany the petition. We have
described the notice of determination as the taxpayer’s “ticket”
to the Tax Court. Weber v. Commissioner, 122 T.C. 258, 263
(2004). We have held that the absence of a section 6330
determination is grounds for dismissal of a petition that
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