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2000, 2001, 2002, and 2004 to petitioner at the Box 415 address.
On or about February 18, 2007, respondent also issued a notice of
intent to levy to petitioner at the Box 415 address. Respondent
now concedes that this final notice of intent to levy was not
sent by certified mail.
Petitioner did not receive either of the collection notices
respondent mailed. Petitioner became aware of respondent’s
collection attempts only when he discovered that his bank account
had been emptied. Respondent has since refunded the money that
was levied upon in the light of his concession that he had not
sent the notice of intent to levy by certified mail.
Petitioner eventually obtained a copy of the notice of
intent to levy from his bank and, on or about April 17, 2007,
sent Form 12153, Request for a Collection Due Process Hearing, to
respondent’s Appeals Office. On May 2, 2007, respondent’s
Appeals Office sent petitioner a letter informing him that the
levy was valid. On May 8, 2007, petitioner timely filed a
petition contesting respondent’s determination.
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise that jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The
Court’s jurisdiction under sections 6320 and 6330 depends upon
the issuance of a valid notice of determination and the filing of
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