William C. Thompson v. Commissioner of Internal Revenue

This disposition is not appropriate for publication and is not precedent*
except as provided by 9th Cir. R. 36-3.
The panel unanimously concludes this case is suitable for decision**
without oral argument and, therefore, denies Thompson’s request. See Fed. R.
App. P. 34(a)(2).
NOT FOR PUBLICATION
UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
WILLIAM C. THOMPSON,
Petitioner - Appellant,
v.
COMMISSIONER OF INTERNAL
REVENUE,
Respondent - Appellee.
No. 11-73535
Tax Ct. No. 11905-11L
MEMORANDUM*
Appeal from a Decision of the
United States Tax Court
Submitted June 26, 2012**
Before: SCHROEDER, HAWKINS, and GOULD, Circuit Judges.
William C. Thompson appeals pro se from the Tax Court’s decision
dismissing his appeal concerning tax years 1993-2004 and 2006 for lack of subject
matter jurisdiction. We have jurisdiction under 26 U.S.C. § 7482(a). We review
FILED
JUL 05 2012
MOLLY C. DWYER, CLERK
U .S. C OU R T OF APPE ALS

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11-73535 2
de novo. Gorospe v. Comm’r, 451 F.3d 966, 968 (9th Cir. 2006). We affirm.
The Tax Court properly determined that it lacked jurisdiction because no
notice of determination was issued for the tax years in question. See 26 U.S.C.
§§ 6320(c), 6330(d)(1) (conferring jurisdiction to the Tax Court for review of a
levy or lien notice only after the IRS issues a determination based upon a collection
due process hearing concerning the taxable period to which the unpaid tax relates);
Gorospe, 451 F.3d at 968 (Tax Court’s subject matter jurisdiction is statutorily
limited by Title 26 of the United States Code).
Thompson’s contentions concerning 26 U.S.C. § 7122 are unpersuasive.
AFFIRMED.

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