John Ballard - Page 8




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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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