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petition. Id. at 162. In deciding whether we had jurisdiction
over the resulting section 6330 proceeding, we stated that,
consistent with our approach in deficiency cases, we would only
examine the notice of determination to decide whether it was
valid for jurisdictional purposes and that we would not look
behind the notice to assess its validity. Id. at 163-164; see
also Offiler v. Commissioner, supra at 498. We further stated:
Whether there was an appropriate hearing opportunity,
or whether the hearing was conducted properly * * *, or
whether any of the other nonjurisdictional provisions
of section 6330 were properly followed, will all be
factors that we must take into consideration under
section 6330 in deciding such cases. But none of these
factors should preclude us from exercising our
jurisdiction under section 6330(d), in order to resolve
the underlying dispute in a fair and expeditious
manner.
Lunsford v. Commissioner, supra at 164. Accordingly, we held
that if Appeals issues a notice of determination that clearly
embodies the Appeals officer’s determination concerning
collection by way of levy and the taxpayer timely files a
petition contesting the determination, then regardless of whether
the taxpayer was given an appropriate hearing opportunity, we
have jurisdiction to review the determination. Id. at 165.
Although neither Lunsford nor Craig is exactly on point, the
facts of this case more closely resemble those of Lunsford than
Craig. Petitioners requested a section 6330 hearing, but no
Appeals hearing was conducted. Appeals then issued a notice of
determination. The notice of determination is valid on its face,
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