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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 officer
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Last modified: November 10, 2007