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review with the Tax Court or Federal District Court, as may be
appropriate. See Orum v. Commissioner, 123 T.C. 1, 7-8 (2004),
affd. 412 F.3d 819 (7th Cir. 2005); Kennedy v. Commissioner, 116
T.C. 255, 260 (2001).
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). It
is well settled that the Court’s jurisdiction under sections 6320
and 6330 depends upon the issuance of a valid notice of
determination and the filing of a timely petition for review.
Sec. 6330(d)(1); Prevo v. Commissioner, 123 T.C. 326, 328 (2004);
Orum v. Commissioner, supra. Respondent’s issuance of a decision
letter (as opposed to a notice of determination) is not
conclusive with respect to the question of whether the Court has
jurisdiction in this case.
D. The Parties’ Positions
1. Respondent
Relying on section 301.6320-1(b)(1) and (2), Proced. &
Admin. Regs., respondent asserts that, because petitioner failed
to submit to respondent a request for an administrative hearing
in respect of the Florida lien filed in October 2002, the Appeals
Office was not obliged to provide petitioner with an
administrative hearing under section 6320 in response to
petitioner’s challenge to the Illinois lien filed in February
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