
    Patrick E. RUDD, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent.
    No. 03-1688.
    United States Court of Appeals, First Circuit.
    Feb. 24, 2004.
    Patrick Edwin Rudd on brief, pro se.
    Robert L. Baker, Attorney, Tax Division, Department of Justice, Frank P. Cihlar, Attorney, Tax Division, Department of Justice, and Eileen J. O’Connor, Assistant Attorney General, on brief, for appellee.
    Before LYNCH, LIPEZ and HOWARD, Circuit Judges.
   PER CURIAM.

Patrick E. Rudd has appealed an order of the United States Tax Court that dismissed his petition, purportedly filed pursuant to 26 U.S.C. § 6330(d), for lack of jurisdiction. We review, de novo, legal interpretations of the Tax Court, such as this jurisdictional determination. See Capital Video Corp. v. Comm’r, 311 F.3d 458, 463 (1st Cir.2002). We affirm.

We conclude that the Tax Court correctly ruled that its jurisdiction under § 6330(d) depends upon the issuance of a valid notice of determination by the IRS’s Office of Appeals and the filing of a timely petition for review. This jurisdictional ruling is in accord with the statutory language of § 6330(d) and is consistent with prior tax court rulings and the Tax Court Rules of Practice and Procedure. See, e.g., Moorhous v. Comm’r, 116 T.C. 263, 269, 2001 WL 406389 (2001); Rule 330(b). Rudd makes no cogent opposing argument. Because the respondent Commissioner has not issued any notice of determination with respect to Rudd’s tax liability for 1989, the Tax Court correctly dismissed Rudd’s petition for lack of jurisdiction.

The order of dismissal is affirmed.  