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under section 6330(d) “is dependent on the issuance of a valid
notice of determination and a timely petition for review.”
Offiler v. Commissioner, 114 T.C. 492, 498 (2000). If the
Appeals Office did not make a determination with respect to a
particular taxable period under section 6330, the absence of a
determination is grounds for dismissal of a petition regarding
such period. See id.
In this case, petitioner’s amended petition covered the
period from 1993 to the present. Respondent’s determination
under section 6330, however, only addressed 1993 and 1994, the
only years as to which respondent issued final notices of intent
to levy. Respondent issued no notices of intent to levy and made
no determination under section 6330 for years after 1994. We
hold, therefore, that we lack jurisdiction under section 6330
over any taxable years other than 1993 and 1994.
II. Respondent’s Motion
A. Summary Adjudication
Section 6330(a) provides that no levy may be made on any
property or right to property of any person unless the Secretary
has notified such person in writing of their right to a hearing
before the levy is made. If the person makes a request for a
hearing, a hearing shall be held by the Internal Revenue Service
Office of Appeals. Sec. 6330(b)(1). At the hearing, a taxpayer
may contest the existence and amount of the underlying tax
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