116 T.C. No. 20
UNITED STATES TAX COURT
DUDLEY AND DOROTHY MOORHOUS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10761-00L. Filed April 23, 2001.
On Mar. 16, 1999, R mailed to P-H a final notice
of intent to levy concerning P-H’s unpaid tax
liabilities for the years 1987 through 1992 and 1997.
On Apr. 27, 1999, R mailed to P-W a final notice of
intent to levy concerning P-W’s unpaid tax liabilities
for the years 1989 through 1992. On May 10, 1999, Ps
filed a joint request for an administrative hearing
with the Internal Revenue Service Office of Appeals
(Appeals Office). P-H failed to file his request for
an administrative hearing within the 30-day period
prescribed in sec. 6330, I.R.C.
Despite P-H’s failure to file a timely request for
an Appeals Office hearing, R granted P-H a so-called
equivalent hearing. P-W was granted an administrative
hearing pursuant to sec. 6330, I.R.C. On Oct. 6, 2000,
R issued a “decision letter” to P-H stating that R
would proceed with collection against him. On Oct. 6,
2000, R issued a determination letter to P-W stating
that R would proceed with collection against her and
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