Prakasam

MEMORANDUM **

Felix Kelly Prakasam and Liliana P. Prakasam appeal pro se from the tax court’s order dismissing for lack of jurisdiction their action contesting an adverse decision letter issued following their untimely request for a collection due process (“CDP”) hearing for tax years 1995 and 1996. We have jurisdiction pursuant to 26 U.S.C. § 7482 . We review a tax court’s legal conclusions de novo and its findings of fact for clear error. Charlotte’s Office Boutique, Inc. v. Comm’r, 425 F.3d 1203, 1211 (9th Cir.2005). We review for abuse of discretion a tax court’s denial of a motion to reconsider. Parkinson v. Comm’r, 647 F.2d 875, 876 (9th Cir.1981) (per curiam). We affirm.

Because the Prakasams did not request a CDP hearing within thirty days of the certified mailing of the notices of deficiency or the notices of federal tax lien filed against them, the tax court properly held that they were not entitled to a CDP hearing. See 26 U.S.C. § 6212 (b)(2) (permitting the Commissioner to issue notice of deficiency by certified mail to taxpayer’s last known address); 26 U.S.C. § 6320 (a)(3)(B) (permitting taxpayer to request a CDP hearing within thirty days of the lien notice); see…