
    Haidee JOY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
    No. 08-75009.
    United States Court of Appeals, Ninth Circuit.
    Submitted May 24, 2011.
    
    Filed June 7, 2011.
    Haidee Joy, San Diego, CA, pro se.
    Nathan J. Hochman, Esquire, Richard T. Morrison, Esquire, John A. Nolet, Gilbert Steven Rothenberg, Esquire, Deputy Assistant Attorney General, U.S. Department of Justice, Robert R. Di Trolio, Esquire, Clerk, U.S. Tax Court, Donald L. Korb, Esquire, Acting Chief Counsel, Washington, DC, for Respondent-Appel-lee.
    Before: PREGERSON, THOMAS, and PAEZ, Circuit Judges.
    
      
       The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
    
   MEMORANDUM

Haidee Joy appeals pro se from the Tax Court’s decision after a trial upholding the IRS Office of Appeals’ determination sustaining a tax lien for her unpaid federal income taxes for years 1992, 1993, and 1995. She also appeals from the Tax Court’s decision dismissing for lack of jurisdiction her challenges concerning years 1987 through 1990, and concerning the proposed levy action for years 1992, 1993, and 1995. We have jurisdiction under 26 U.S.C. § 7482(a)(1). We review de novo the Tax Court’s legal conclusions and for clear error its factual findings. Charlotte’s Office Boutique, Inc. v. Comm’r, 425 F.3d 1203, 1211 (9th Cir.2005). We affirm.

The Tax Court properly granted the Commissioner of Internal Revenue’s motion to dismiss for lack of jurisdiction as to Joy’s challenges concerning years 1987 through 1990, because there was no notice of determination for these years. See 26 U.S.C. §§ 6320(c), 6330(d)(1); T.C. R. 330(b). The Tax Court also properly granted the Commissioner’s motion to dismiss for lack of jurisdiction as to Joy’s challenges to the proposed levy action for years 1992, 1993, and 1995, because the Office of Appeals’ decision addressing the equivalent hearing was not appealable. See Treas. Reg. § 301.6330-l(i)(2) Q & A 16.

Contrary to Joy’s contention, the statute of limitations did not bar collection of the unpaid tax liabilities for years 1992, 1993, and 1995, because Joy agreed to extend the statute of limitations in conjunction with the execution of an installment agreement. See 26 U.S.C. § 6502(a)(2)(A). Further, the Tax Court did not clearly err by finding that the tax liabilities were individual income tax liabilities rather than employer tax liabilities, as reflected in the Form 900 Waiver that Joy signed, and Joy failed to present any contrary evidence.

We do not consider issues that Joy failed to raise in the collection due process hearing. See Treas. Reg. § 301.6330 — 1(f)(2) Q & AF3.

AFFIRMED. 
      
       This disposition is not appropriate for publication and is not precedent except as provided by 9 th Cir. R. 36-3.
     