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Petitioner sought reconsideration from the Internal Revenue
Service’s (IRS) Collection Appeals Program. On May 8, 2007, the
Collection Appeals Program issued a closing letter which stated
that following a review of petitioner’s case, it was determined
that the area director was correct that the NFTLs should be
filed. In addition, the letter served as notification that the
matter was closed in the Appeals Office. On May 30, 2007,
petitioner filed with this Court a petition challenging the lien
determinations with respect to income tax the McMahans owed for
1993, 1994, and 1995.
OPINION
This Court is a court of limited jurisdiction, and we may
exercise judgment only to the extent authorized by Congress.
Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
Section 6321 provides that all property and rights to
property of a taxpayer become subject to a lien when demand for
payment of taxes has been made and the taxpayer fails to pay
those taxes. Section 6320(a) provides that the Secretary shall
furnish the taxpayer with a written notice within 5 business days
after the NFTL is filed. This written notice informs the
taxpayer of the right to request an administrative hearing on the
matter. The taxpayer then may seek judicial review of the
determination made after the hearing. See Davis v. Commissioner,
115 T.C. 35, 37 (2000); Goza v. Commissioner, 114 T.C. 176, 179
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Last modified: March 27, 2008