Daniel and Sally A. Holguin - Page 11

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          such a hearing within 30 days from the date of respondent’s                 
          February 5, 1999 notice of intent to levy concerning her taxable            
          years 1994, 1995, and 1996, which notified her of her right to an           
          Appeals Office hearing.  See sec. 6330(a)(3)(B); sec. 301.6330-             
          1(c)(2), Q&A-C7, Proced. & Admin. Regs.                                     
               Instead of an Appeals Office hearing, respondent held an               
          equivalent hearing with respect to respondent’s February 5, 1999            
          notice of intent to levy concerning Ms. Holguin’s taxable years             
          1994, 1995, and 1996.  See sec. 301.6330-1(i)(1), Proced. &                 
          Admin. Regs.  Consequently, respondent issued a decision letter             
          to Ms. Holguin instead of a notice of determination.  Id.  That             
          letter was not, and did not purport to be, a determination under            
          section 6330(d).  See, e.g., Moorhous v. Commissioner, supra at             
          270.                                                                        
               We conclude that we do not have jurisdiction over Ms.                  
          Holguin.12  See sec. 6330(d)(1); Moorhous v. Commissioner, supra.           
          We shall grant respondent’s motion to dismiss for lack of juris-            
          diction as to Ms. Holguin.                                                  








               12We note that petitioners do not object to the Court’s                
          granting respondent’s motion to dismiss for lack of jurisdiction            
          as to Ms. Holguin.                                                          





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