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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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