United States Tax Court November 30, 2001, No. 18071-99L (Lunsford v. Comm'r)

Halpern, J.,

concurring: I concur with the majority that we have jurisdiction to hear an appeal from a section 6330(c)(3) determination notwithstanding that no section 6330(b) hearing was held. I write separately to lend support to the majority’s conclusion and to offer some comments concerning our authority to dictate to respondent the nature of the hearing required by section 6330(b).

I.