- 7 -
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
follows:
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,
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011