- 16 - Our jurisdiction under section 6015(e)(1) is not limited to an appeal or review of the administrative determination. Rather, section 6015(e)(1) gives the Tax Court jurisdiction to determine the appropriate relief available to a taxpayer under section 6015, including equitable relief under section 6015(f). We think there is no convincing reason to exercise our jurisdiction under section 6015(e)(1) to determine the appropriate relief available to a taxpayer under section 6015 differently from our jurisdiction under section 6213(a) to redetermine a deficiency in tax. Ewing v. Commissioner, supra at 37. Nor is there any convincing reason to exercise our jurisdiction under section 6015(e)(1) differently in determining the appropriate relief available to a taxpayer under section 6015(f) from determining the relief available under section 6015(b) and (c). Moreover, the lien and levy procedures under sections 6320 and 6330 are more extensive than the procedures for seeking relief from liability under section 6015. Taxpayers in a lien or levy action are entitled to participate in a hearing at the Appeals Office nearest their residence. Katz v. Commissioner, 115 T.C. 329, 337-338 (2000); sec. 301.6330-1(d)(2), Q&A-D6 and D7, Proced. & Admin. Regs. The hearing, whether conducted face to face or by telephone or correspondence, affords the taxpayer and the Appeals officer the opportunity to discuss the issues and to fully develop and clarify the facts. The Appeals officerPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007