are void and of no effect. Our ruling in Lundsford v.
Commissioner, 117 T.C. 159, 165 (2001) (notice of determination
issued without proper hearing held to be valid for purposes of
Tax Court jurisdiction) does not preclude that result, as it is
bankruptcy law, which is extrinsic to the procedures specified in
section 6330, that leads to our conclusion. Given the invalidity
of the notices of determination, we shall dismiss these cases for
lack of jurisdiction on the Court’s own motion.
To reflect the foregoing,
Orders of dismissal shall be
entered denying respondent’s
motions to dismiss for lack of
jurisdiction, and these cases shall
be dismissed for lack of
jurisdiction on the Court’s own
motion.
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Last modified: May 25, 2011