Katherine Cowan - Page 10

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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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