John Henry Ryskamp appeals pro se from the Tax Court’s order dismissing his action for lack of subject matter jurisdiction. 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 we affirm. The Tax Court properly concluded that it lacked jurisdiction because Ryskamp was never issued a notice of deficiency or a notice of determination. See 26 U.S.C. §§ 6213(a), 6330(d); see also 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); Abrams v. Comm’r, 814 F.2d 1356, 1356-57 (9th Cir.1987) (per curiam) (<HOLDING>). We deny Ryskamp’s motions filed on June
holding that a prefiling notification letter from the internal revenue service was not a notice of deficiency and therefore the tax court had no jurisdiction over the taxpayers petition holding that overvaluation penalty did not apply where the taxpayers conceded other grounds of adjustment in the notice of deficiency including that they lacked a profit objective that the property at issue was not qualifying property and that the property was not placed in service holding that following confirmation of the debtors chapter 11 plan the internal revenue service could collect a nondischargeable tax claim that was not listed in the irss bankruptcy claim holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice holding that the debtor lacked standing to bring a claim against the internal revenue service for the improper assessment of a tax deficiency because the cause of action was the property of the estate and had not been abandoned to the debtor