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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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