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towards his outstanding tax liabilities. Mr. Blais rejected
the proposed installment agreement because it would not allow
petitioner’s outstanding tax liabilities to be paid within the
applicable periods of limitation. Having previously upheld the
rejection of the 2003 offer, Mr. Blais further concluded that the
NFTL was an appropriate collection action with respect to
petitioner’s outstanding tax liabilities, and he caused the
above-referenced notice of determination that forms the basis for
this case to be issued on January 5, 2005.
Discussion
Petitioner availed himself of three separate, albeit more or
less related, administrative appeals that preceded this
proceeding. He appealed Mr. Barry’s (the revenue officer)
decision to file the NFTL; he appealed Mr. Barry’s rejection of
the 2003 offer; and he challenged the filing of the NFTL in a
section 6320(c) hearing. Technically, only his challenge to the
filing of the NFTL is reviewable in this proceeding. After all,
as noted in countless opinions, we are a Court of limited
jurisdiction, and our jurisdiction in this proceeding is
established exclusively, and limited, by section 6330(d).
Consequently, even though the appeal of the rejection of the
2003 offer and petitioner’s request for a section 6320(c) hearing
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