- 8 - “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:Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007