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determination of the correct tax liability for a year
that has been placed in issue." [Hill v. Commissioner,
95 T.C. 437, 439-440 (1990).]
Thus, section 6214(b) does not foreclose our authority (i) to
consider facts and issues in a nondeficiency year and on the
basis thereof compute the tax liability for that year (regardless
of the tax liability reported by the taxpayer or assessed by the
Commissioner), or (ii) to employ the recomputed tax liability in
redetermining the tax liability for the year for which a
deficiency was determined. The limiting conditions of section
6214(b) are that the computation of the other year's tax
liability be necessary to the redetermination of the tax
liability at issue and that our recomputation not constitute a
determination of the other year's liability for any other
purpose.
There is no statutory provision comparable to section
6214(b) that limits the jurisdiction granted by section
6330(d)(1)(A). Nonetheless, our holding conforms to the
principles of section 6214(b). We conclude that our jurisdiction
under section 6330(d)(1)(A) extends to the consideration of facts
and issues in a nondetermination year only insofar as the tax
liability for that year may affect the appropriateness of the
collection action for the determination year. In exercising that
jurisdiction, we do not determine whether any collection action
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