Citation Codes Equivalent Citations citation codes Docket Number No. 07-73786. Attorney(S) John Ballard, Phelan, CA, pro se. Janet A. Bradley, Esquire, Eileen J. O'Connor, Esquire, Bridget Maria Rowan, U.S. Department of Justice, Robert R. Di Trolio, Esquire, U.S. Tax Court, Donald L. Korb, Esquire, Acting Chief Counsel, Washington, DC, for Respondent-Appellee. Judges Diarmuid Fionntain O'Scannlain Jay S. Bybee Consuelo Maria Callahan Acts Internal Revenue Code — Procedure And Administration — Judicial Proceedings — Court Review Of Tax Court Decisions — Courts Of Review Internal Revenue Code — Procedure And Administration — Assessment — Deficiency Procedures In The Case Of Income, Estate, Gift, And Certain Excise Taxes — Restrictions Applicable To Deficiencies; Petition To Tax Court Internal Revenue Code — Procedure And Administration — Collection — Seizure Of Property For Collection Of Taxes — Due Process For Collections — Notice And Opportunity For Hearing Before Levy See more information ... Smart Summary Please sign up to generate summary. John BALLARD, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. MEMORANDUM This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3. John Ballard appeals pro se from the tax court's order dismissing the action for lack of subject matter jurisdiction. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo. Abrams v. Comm'r, 814 F.2d 1356, 1357 (9th Cir. 1987) (per curiam). We affirm. The tax court properly concluded that it lacked jurisdiction because Ballard was never issued a Notice of Deficiency or a Notice of Determination. See 26 U.S.C. §§ 6213(a), 6330(d); Abrams, 814 F.2d at 1357 (holding that a pre-filing notification letter from the Internal Revenue Service was not a Notice of Deficiency, and therefore, the Tax Court had no jurisdiction over the taxpayer's petition). Ballard's remaining contentions are unpersuasive. AFFIRMED.