- 3 - 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, 179Page: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008