Rockie D. Elmore - Page 7

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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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