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obtain verification from the Secretary that the requirements of
any applicable law or administrative procedure have been met.
Further, section 6330(c)(3) lists the factors that an Appeals
officer must consider in making his or her determination.
When the Appeals Office issues a determination letter to a
taxpayer following an administrative hearing regarding a notice
of intent to levy, section 6330(d)(1) provides that the taxpayer
will have 30 days following the issuance of such determination
letter to file a petition for review with the Tax Court or
Federal District Court, as appropriate. See Offiler v.
Commissioner, 114 T.C. 492, 498 (2000). We have held that this
Court’s jurisdiction under section 6330 depends upon the issuance
of a valid determination letter and the filing of a timely
petition for review. See Sarrell v. Commissioner, 117 T.C. 122,
125 (2001); Moorhous v. Commissioner, 116 T.C. 263, 269 (2001);
Offiler v. Commissioner, supra at 498; see also Rule 330(b).
As indicated, petitioner challenges the validity of the
notice of determination on the ground that it was not properly
signed. In addressing petitioner’s contention, we note as an
initial matter that section 6330 does not require that a notice
of determination be signed. Cf. Pendola v. Commissioner, 50 T.C.
509, 513-514 (1968) (a notice of deficiency need not be signed in
order to be valid); Fox v. Commissioner, T.C. Memo. 1993-277,
affd. without published opinion 69 F.3d 543 (9th Cir. 1995)
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