Cir

MEMORANDUM

Ginn Doose appeals pro se from the Tax Court’s decision, after a trial, upholding the Internal Revenue Service’s (“IRS”) determination to collect by levy unpaid federal income taxes for 2002, 2004, and 2005. She also appeals from the Tax Court’s decision dismissing for lack of jurisdiction her challenge concerning tax year 2006. We have jurisdiction under 26 U.S.C. § 7482 (a)(1). We review de novo both the Tax Court’s dismissal for lack of subject matter jurisdiction, Gorospe v. Comm’r, 451 F.3d 966, 968 (9th Cir.2006), and its legal conclusions following a trial, Charlotte’s Office Boutique, Inc. v. Comm’r, 425 F.3d 1203, 1211 (9th Cir.2005). We affirm.

The Tax Court properly determined that the IRS did not abuse its discretion by sustaining the proposed levy after Doose rejected the IRS’s proposed payment plan taking into account her economic situation and failed to propose a collection alternative. See Fargo v. Comm’r, 447 F.3d 706, 709 (9th Cir.2006) (reviewing Commissioner’s actions for an abuse of discretion); see also 26 U.S.C. § 6330 (c)(3)(C); Sinyard v. Comm’r, 268 F.3d 756, 758 (9th Cir.2001) (“The discharge by a third person of an obligation to him is…