Cir

ORDER

Commissioner of Internal Revenue’s motion to amend the opinion is granted. The memorandum disposition filed on July 5, 2012, is withdrawn. A new memorandum disposition will be filed concurrently with this order.

Having not raised an issue of fact or law that would warrant relief, Thompson’s petition for panel rehearing is denied.

No further filings will be entertained in this closed appeal.

MEMORANDUM

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 de novo. Gorospe v. Comm’r, 451 F.3d 966, 968 (9th Cir.2006). We affirm.

We previously issued a memorandum disposition affirming the Tax Court’s decision dismissing Thompson’s action for lack of subject matter jurisdiction because no notice of determination had been issued for the tax years in question. Subsequently, Commissioner of Internal Revenue (“CIR”) filed a motion stating that, despite its previous representations, a notice of determination had been issued on August 11, 2009. CIR argued that the Tax Court still lacked jurisdiction because…