OPINION
THOMAS, Circuit Judge:
This appeal presents the question, inter alia, of whether the Tax Court had jurisdiction in a hearing conducted pursuant to 26 U.S.C. § 6330 to review the Internal Revenue Service's failure to comply with its statutory mandate under 26 U.S.C. § 6335(f). We conclude that it did, and we affirm the judgment of the Tax Court.
I
Michael and Gina Zapara owe the IRS over $450,000 for failing to report...
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