Cir

MEMORANDUM

Ramnik and Mrudula Trivedi appeal pro se from the Tax Court’s decision dismissing for lack of subject matter jurisdiction their petition concerning tax years 1992 and 1993. We have jurisdiction under 26 U.S.C. § 7482 (a)(1). We review de novo, Gorospe v. Comm’r, 451 F.3d 966, 968 (9th Cir.2006), and affirm.

The Tax Court properly dismissed the Trivedis’ petition for lack of subject matter jurisdiction because the Trivedis did not file their petition within 30 days of a notice of determination concerning a notice of lien or intent to levy. See 26 U.S.C. § 6330 (d)(1) (establishing a 30-day requirement for appealing a notice of determination concerning a notice of intent to levy to the Tax Court); Gorospe, 451 F.3d at 968 (the Tax Court is a court of limited jurisdiction, and its subject matter jurisdiction is defined by Title 26 of the United States Code; a taxpayer may seek judicial review in the Tax Court after he or she appeals a notice of lien or intent to levy and receives a determination from the IRS, as provided for in 26 U.S.C. § 6330 ); see also 26 U.S.C. § 6320 (c) (§ 6330(d) applies to notices of lien).

Contrary to the Trivedis’s contention, the November…