Claude E. and Dana L. Salazar - Page 9

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               Respondent’s rejection letter addressing Mr. Salazar’s                 
          employment tax liabilities does not include the information that            
          a notice of determination is required to include.  See sec.                 
          301.6330-1(e)(3), Q&A-E8, Proced. & Admin. Regs.  For example,              
          the letter does not address the requirements of applicable law or           
          administrative procedure, the balance between the efficient                 
          collection of taxes and the intrusiveness of the proposed levy,             
          or any appellate procedure available to petitioners.  The                   
          rejection letter also fails to state that respondent intends to             
          proceed with the collection of taxes in issue.  The letter simply           
          rejects petitioners’ offer-in-compromise and requests that                  
          petitioners voluntarily pay their account in full.  We conclude,            
          therefore, that the rejection letter is not a notice of                     
          determination for purposes of section 6330 and that we lack                 
          jurisdiction over petitioners’ claim regarding Mr. Salazar’s                
          employment tax liabilities under section 6330.                              
               Section 7436(a), which gives us limited jurisdiction over              
          employment tax disputes regarding a worker’s employment status,             
          does not solve the jurisdictional problem that petitioners                  
          present, nor does it serve as an independent basis for asserting            
          jurisdiction over Mr. Salazar’s employment tax liabilities.  The            
          issue raised in the petition does not involve any dispute                   
          regarding employment status, and respondent has not made a                  






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