- 7 -
jurisdiction under section 6330(d)(1)(A). Lunsford v. Commis-
sioner, 117 T.C. 159, 164 (2001).
The notice of determination in the instant case stated:
Since you did not respond to the Appeals Officer’s
request for information nor attend the scheduled con-
ference on October 9, 2001, we will return you [sic]
case to the Collection function for collection appro-
priate action.
We hold that the notice of determination embodies a determination
to proceed with the collection of petitioner’s tax liability for
each of his taxable years 1990, 1991, 1992, 1993, and 1996. We
further hold that we have jurisdiction to review that determina-
tion in the instant case.3
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing,
An order denying petitioner’s
motion will be issued.
3Respondent’s acknowledgement in respondent’s response to
petitioner’s motion that the notice of determination “did not
contain all the statements required by Treas. Reg. � 301.6330-
1(e)(3) Q&A-E8" does not affect our jurisdiction to review the
determination in that notice to proceed with the collection of
petitioner’s tax liability for each of his taxable years 1990,
1991, 1992, 1993, and 1996.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011