Does the United States Tax Court have jurisdiction to review a collection due process hearing appeal if there is no longer an ongoing levy? Specifically, does the term "determination" under 26 U.S.C. § 6330(d)(1) encompass all issues resolved at a hearing or only the binary decision on whether a levy may proceed? The Court must decide if the abandonment of a levy moots the proceedings or leaves the court with jurisdiction to resolve underlying tax liability disputes.

• A "determination" under 26 U.S.C. § 6330(d)(1) is simply a binary decision as to whether a levy may go forward.
• If there is no longer a proposed levy, there is no adverse determination of which the taxpayer may seek review in the Tax Court.
• The Tax Court's jurisdiction is limited because it cannot order refunds or issue declaratory judgments independent of an ongoing collection effort.

• A "determination" encompasses the appeals officer's resolution of all issues raised by the taxpayer during the collection due process hearing, including challenges to underlying tax liability.
• The Tax Court retains jurisdiction to review conclusions regarding tax liability—such as the allocation of estimated tax payments—even if the IRS abandons the possible levy.
• A victory in the Tax Court would provide a declaration that could be used to force the IRS to refund overpayments it wrongly withheld.

• The Tax Court is a court of limited jurisdiction, as established in *Commissioner v. McCoy*.
• Under 26 U.S.C. § 6330(d)(1), the Court's jurisdiction is limited to reviewing a "determination" made by an appeals officer in a collection due process hearing.
• The Court defines "determination" as the binary output—the decision whether a levy may proceed—rather than the "considerations" or inputs used to reach that decision under 26 U.S.C. § 6330(c)(3).
• Statutory context supports this narrow view, noting that the default rule under 26 U.S.C. § 7421(a) requires taxpayers to pay disputed taxes before pursuing a challenge.
• The Court notes that 26 U.S.C. § 6330 is titled "Notice and opportunity for hearing before levy" and focuses exclusively on the proposed levy, including requirements in 26 U.S.C. § 6330(a)(2) and (a)(3)(C).
• The scope of the hearing tracks its purpose; taxpayers may raise only issues pertaining to the levy, such as "challenges to the existence or amount of the underlying tax liability" under 26 U.S.C. § 6330(c)(2)(B).
• Under 26 U.S.C. § 6330(e)(1), the Tax Court may only enjoin actions "in respect of the unpaid tax or proposed levy to which the determination being appealed relates," and cannot order refunds or issue declaratory judgments without a levy.
• Because there was no longer a basis for a levy once respondent's balance reached zero, there was no relevant "determination" left for the Tax Court to review.