the hearing and responds to any offers or objections made by the complainant. Section 6330(d) provides for judicial review of a Notice of Determination as follows: (a) Proceeding After Hearing— (1) Judicial review of determination. — The person may, within 30 days of a determination under this section,- appeal such determination— (A) to the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter); or (B) if the Tax Court does not have jurisdiction of the underlying tax liability, to a district c 8 (W.D.Tenn.2002) (noting that the court is confined to the administrative record in considering plaintiffs appeal pursuant to § 6330(d)); Dudley’s Commerical and Industrial Coating, Inc. v. U.S.I.R.S., 292 F.Supp.2d 976, 984, 2003 WL 1950231 at *9 (M.D.Tenn.2003) (<HOLDING>); Herycyk v. United States, 2001 WL 1836194 at
holding that in its review of the irs exercise of discretion the court is limited to a review of the administrative record holding that there is no right to habeas review of administrative evidentiary determinations before a district court where direct review of the administrative proceedings is available in the appellate courts holding that a district courts review of a  6330d appeal is limited to the administrative record and the parties are not entitled to discovery holding that judicial review of decisions of military correction boards is review of the administrative record conducted under the administrative procedure act holding that because here the statutes in issue provide for judicial review via citizen suit provisions yet do not set forth a standard for that review judicial review is limited to apa review on the administrative record