- 30 -
necessary.” Sec. 6330(c)(3); see Washington v. Commissioner, 120
T.C. 114, 126 (2003) (Washington I) (Halpern, J., concurring).
Thus, the components of subparagraphs (A), (B), and (C) of
section 6330(c)(3) are part of “the determination” of the Appeals
officer and “the determination” that the Tax Court has
jurisdiction over pursuant to section 6330(d)(1). See
Washington I, supra at 129 (Halpern, J., concurring); id. at 131
(Beghe, J., concurring). Accordingly, the section 6330
determination, and our review of the section 6330 determination,
consists of more than merely whether or not a notice of intent to
levy (or lien) should be sustained and whether the Commissioner
can proceed with collection. See also Washington I; Katz v.
Commissioner, 115 T.C. 329 (2000); Krueger v. Commissioner, T.C.
Memo. 2005-105; Skrizowski v. Commissioner, T.C. Memo. 2004-229;
sec. 301.6330-1(e)(3) Q&A-E8(i), -E11, Proced. & Admin. Regs.
At the hearing, petitioner contended that she was not liable
for any interest accruals between December 19, 1997, and July 3,
2000. Majority op. p. 4. In her requests for a hearing,
petitioner claimed that she did not owe the money respondent was
seeking to collect. Majority op. pp. 3-4. Accordingly, the
determination included whether petitioner was liable for any
interest accruals between December 19, 1997, and July 3, 2000,
and whether she did owe the money respondent sought to collect--
that when the 1999 overpayment was applied to 1992 there was an
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