Michael Eisler - Page 4

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               The petition is dated August 9, 2006, and was received by              
          the Court and filed on August 22, 2006.  The envelope in which              
          the petition was enclosed bears a U.S. Postal Service postmark of           
          August 15, 2006.                                                            
               The notice of determination was sent to petitioner’s last              
          known address.                                                              
               The petition was filed more than 30 days after respondent              
          sent the notice of determination.                                           
               Section 6330(d)(1) provides that this Court has jurisdiction           
          to review a determination under section 6330 if the taxpayer                
          appeals “within 30 days of [the] determination”.                            
               This Court’s jurisdiction in such cases depends on the                 
          issuance of a valid notice of determination and the filing of a             
          timely petition for review.  Weber v. Commissioner, 122 T.C. 258,           
          261 (2004).                                                                 
               Section 6330(d) does not specify how the Commissioner is to            
          give notice of a determination under that section.  We have held            
          the method that the Congress specifically authorized in                     
          subsections (a) and (b) of section 6212 for sending notices of              
          deficiency should suffice for section 6330(d) notices of                    
          determination.  Id.  Accordingly, a section 6330(d) notice of               
          determination is sufficient if it is sent by certified or                   

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