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177, 179 (1960). Thus, the threshold issue for decision is
whether this Court has jurisdiction in this case.
The Tax Court is a court of limited jurisdiction, and we may
exercise that jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Petitioner contends that this Court has jurisdiction in this case
to review a collection action under section 6330.
Section 6330 entitles a taxpayer to notice of the taxpayer’s
right to request a hearing before certain levy actions are taken
by the Commissioner in furtherance of collection from the
taxpayer of unpaid Federal taxes. If a hearing is requested, the
Appeals officer conducting the hearing must verify that the
requirements of any applicable law or administrative procedure
have been met. Sec. 6330(c)(1). The taxpayer requesting the
hearing may raise “any relevant issue relating to the unpaid tax
or the proposed levy”. Sec. 6330(c)(2)(A). The taxpayer may
raise challenges “to the existence or amount of the underlying
tax liability”, however, only if he “did not receive any
statutory notice of deficiency for such tax liability or did not
otherwise have an opportunity to dispute such tax liability.”
Sec. 6330(c)(2)(B). Following the hearing, the Appeals officer
must determine whether the collection action is to proceed,
taking into account the verification the Appeals officer has
made, the issues raised by the taxpayer at the hearing, and
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