119 T.C. No. 15
UNITED STATES TAX COURT
MICHAEL CRAIG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14649-01L. Filed November 14, 2002.
On Feb. 22, 2001, R mailed to P a final notice of
intent to levy (final notice) for 1990, 1991, and 1992.
On the same day, R mailed to P a final notice for 1995.
On March 17, 2001, P timely requested a hearing under
sec. 6330, I.R.C. (Hearing), as to both final notices.
Subsequently, R’s Appeals officer (A) held with P an
“equivalent hearing” under sec. 301.6330-1(i), Proced.
& Admin. Regs. A informed P at the equivalent hearing
that P was not allowed a Hearing because, A mistakenly
believed, P’s request for a Hearing was untimely. A
later issued to P a decision letter sustaining the
proposed levy.
Held: The determination reflected in the decision
letter, coupled with P’s timely petition to this Court
with respect thereto, serves to invoke this Court’s
jurisdiction under sec. 6330(d)(1), I.R.C.
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