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6015(b) and (c) is not at issue, the Court will review
respondent’s administrative determinations for abuse of
discretion; that is, whether the determinations were arbitrary,
capricious, or without sound basis in fact or law. See Sego v.
Commissioner, 114 T.C. 604, 610 (2000); Woodral v. Commissioner,
112 T.C. 19, 23 (1999). We note that we do not have jurisdiction
under section 6330(d) to review petitioners’ claims contesting
the proposed levy actions for the taxable years 1997 and 1998.
Section 301.6330-1(b), Proced. & Admin. Regs., provides that the
taxpayer must request the section 6330 hearing within the 30-day
period commencing on the day after the date of the notice of
intent to levy. Failure to do so results in the taxpayer’s being
allowed only an “equivalent hearing”. Section 301.6330-1(i)(2),
Q&A-15, Proced. & Admin. Regs., generally provides that a
taxpayer may not obtain court review of the decision following an
equivalent hearing. Petitioners did not file their Forms 12153
within the 30-day period following the 1997 and 1998 notices of
intent to levy. Therefore, we lack jurisdiction to review
respondent’s decision to uphold the levy actions for the taxable
years 1997 and 1998.
Notwithstanding our lack of jurisdiction to review the
upheld levy actions under section 6330 for the taxable years 1997
and 1998, we have statutory jurisdiction to consider petitioners’
challenge to the liens under section 6320, as well as Lois
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