Don Weber II - Page 7

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          proceeding regarding a Federal tax lien by way of the cross-                
          reference contained in section 6320(c).                                     
               We have held that this Court’s jurisdiction under sections             
          6320 and 6330 depends on the issuance of a valid notice of                  
          determination 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).5                          
               Although section 6330(d) does not specify the means by which           
          the Commissioner is required to give notice of a determination              
          made under sections 6320 and 6330, we conclude that the method              
          that Congress specifically authorized for sending notices of                
          deficiency in section 6212(a) and (b) certainly should suffice.             
          Accordingly, we hold that a notice of determination issued                  
          pursuant to sections 6320 and/or 6330 is sufficient if such                 
          notice is sent by certified or registered mail to a taxpayer at             
          the taxpayer’s last known address.  Cf. sec. 6212(b)(1), (3).6              

               5  Petitioner did not raise any challenge to the validity of           
          either of the notices of determination in question.                         
               6  Sec. 6212(b)(1) and (3) provides in pertinent part as               
               SEC. 6212. NOTICE OF DEFICIENCY.                                       
                  *       *       *       *       *       *       *                   
                    (b) Address for notice of deficiency.--                           
                         (1) Income and gift taxes and certain excise                 
                    taxes.–-* * * notice of a deficiency * * * if                     
                    mailed to the taxpayer at his last known address,                 

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