-6-
Commissioner, 85 T.C. 812, 821 (1985); Naftel v. Commissioner, 85
T.C. 527, 529 (1985). The Court will view any factual material
and inferences in the light most favorable to the nonmoving
party. Dahlstrom v. Commissioner, supra at 821; Naftel v.
Commissioner, supra at 529.
B. Our Jurisdiction Under Section 6330
Before the Commissioner may levy on any property or property
right, the taxpayer must be provided written notice of the right
to request a hearing during the 30-day period before the first
levy. Sec. 6330(a). If the taxpayer requests a hearing, an
Appeals officer of the Commissioner must hold the hearing. Sec.
6330(b)(1). Within 30 days of the issuance of the Appeals
officer’s determination, the taxpayer may seek judicial review of
the determination. Sec. 6330(d)(1).
On August 17, 2006, the Pension Protection Act of 2006 (the
PPA), Pub. L. 109-280, 120 Stat. 780, was enacted. PPA sec.
855(a), 120 Stat. 1019, amended section 6330(d)(1), which
provides our jurisdiction to review notices of determination
issued pursuant to section 6330. Before the passage of the PPA,
section 6330(d)(1) provided:
SEC. 6330(d). Proceeding After Hearing.--
(1) Judicial review of determination.–-The person
may, within 30 days of a determination under this
section, appeal such determination–-
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