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Discussion
A. The Federal Tax Lien
Petitioner asks us to direct the IRS to withdraw the tax
lien currently in place for the taxable years 1992, 1993, and
1994. He claims he paid his debt in full and complains that the
lien remains. However, in the context of this action for
redetermination, we lack jurisdiction to consider, much less
grant, the relief requested by petitioner.
The Internal Revenue Service Restructuring and Reform Act of
1998, 112 Stat. 685, Pub. L. 105-206, was enacted into law on
July 22, 1998. Section 3401 of that Act, 112 Stat. 746, grants
this Court jurisdiction to review the Commissioner’s
determination as to the propriety of filing a notice of Federal
tax lien under section 6320 or a proposed levy on property under
section 6330.
In a collection review action, this Court’s jurisdiction
under sections 6320 and 6330 depends, in part, on the issuance of
a notice of determination by respondent’s Office of Appeals after
the taxpayer has requested an administrative hearing following
the issuance by respondent’s collection division of either a
final notice of intent to levy, see sec. 6330(a), or a notice of
filing of Federal tax lien, see sec. 6320(a). See Sarrell v.
Commissioner, 117 T.C. 122, 125 (2001); Moorhous v. Commissioner,
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