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primarily by whether it would be in the interest of justice to
vacate the prior decision. But, we also recognize that
litigation must end at sometime.” Estate of Egger v.
Commissioner, 92 T.C. 1079, 1083 (1989); Manchester Group v.
Commissioner, T.C. Memo. 1997-576.
This Court’s jurisdiction to review certain collection
activity by the Internal Revenue Service depends, in part, upon
the issuance of a valid notice of determination by an Internal
Revenue Service Appeals Officer under section 6320 or 6330.
Secs. 6320(c), 6330(d)(1); Rule 330(b); Offiler v. Commissioner,
114 T.C. 492, 498 (2000). Where the Appeals Office issues a
determination letter, section 6330(d)(1) provides a taxpayer 30
days in which to file a petition for review with the Tax Court.
We have held that the Court’s jurisdiction depends on the
issuance of a valid determination letter and the filing of a
timely petition for review. Kennedy v. Commissioner, 116 T.C.
255, 261 (2001).
Petitioner attached to her amended petition the decision
letter concerning an equivalent hearing she received from
respondent’s Appeals Office. In her amended petition, petitioner
avers that she disagrees with the “determination” relating to the
years 1995, 1996 and 1997 contained in the “Decision Letter
Concerning Equivalent Hearing Under Section 6320 and/or 6330".
The decision letter specifies that it was issued after petitioner
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