Booth

MEMORANDUM **

Steven and Louise Booth appeal pro se from the Tax Court’s order dismissing for lack of jurisdiction their petition for an order ' compelling the Internal Revenue Service (“IRS”) to issue a determination letter regarding lien and levy notices, and from the Tax Court’s order denying their motion for reconsideration. We have jurisdiction pursuant to 26 U.S.C. § 7482 (a). We review de novo the Tax Court’s dismissal for lack of subject matter jurisdiction, Gorospe v. Comm’r, 451 F.3d 966, 968 (9th Cir.2006), and we affirm.

Dismissal was proper because the Booths failed to avail themselves of a collection due process (“CDP”) hearing regarding the initial lien and levy notices, and, thus, the Tax Court lacked jurisdiction to compel a CDP hearing or the issuance of a determination letter that would result from a CDP hearing. See 26 U.S.C. § 6320 (c) (conferring jurisdiction to the Tax Court for review of a lien notice only after a taxpayer requests and receives a CDP hearing and the IRS issues a determination letter based upon the hearing); 26 U.S.C. § 6330 (same for levy notice); see also 26 C.F.R. § 301.6320-1 (b)(2) (requiring taxpayer to request hearing upon filing of…