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“whether any proposed collection action balances the need for the
efficient collection of taxes with the legitimate concern of the
* * * [taxpayer] that any collection action be no more intrusive
than necessary.” Sec. 6330(c)(3).
The Court’s jurisdiction under section 6330 depends upon the
issuance of a valid notice of determination and the filing of a
timely petition for review. Sec. 6330(d)(1); see Orum v.
Commissioner, 123 T.C. 1 (2004), affd. 412 F.3d 819 (7th Cir.
2005); Sarrell v. Commissioner, 117 T.C. 122, 125 (2001);
Moorhous v. Commissioner, 116 T.C. 263, 269 (2001); Offiler v.
Commissioner, 114 T.C. 492, 498 (2000); see also Rule 330(b).
Thus, in the absence of a notice of determination, this Court
lacks jurisdiction.
Petitioner attached to his petition IRS Letter 2081(CG).
Petitioner contends that IRS Letter 2081(CG) constitutes a valid
notice of determination that confers jurisdiction on this Court
under section 6330. We disagree because none of the events
described in section 6330 that lead to a determination which we
have jurisdiction to review have occurred. There has been no
notice of a right to a hearing, no timely request for hearing,
and no determination with respect to the hearing or request for
hearing as required by section 6330. A description of a notice
of determination is found in section 301.6330-1(e)(3), Q&A-E8(i),
Proced. & Admin. Regs., which provides:
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Last modified: November 10, 2007