James R. Kennedy - Page 3




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               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent’s Motion to Dismiss for Lack of Jurisdiction.                 
          Respondent contends that the Court lacks jurisdiction over the              
          petition on the ground that respondent did not issue a                      
          determination letter to petitioner pursuant to section 6320 or              
          6330.  As explained in detail below, insofar as petitioner seeks            
          review of a notice of the filing of a notice of lien pursuant to            
          section 6320, we will dismiss this case for lack of jurisdiction            
          on the ground that respondent failed to mail the notice required            
          by section 6320(a) to petitioner at his last known address and,             
          therefore, petitioner had no opportunity to request an                      
          administrative hearing.  Further, insofar as petitioner seeks               
          review of a notice of intent to levy pursuant to section 6330, we           
          will dismiss this case for lack of jurisdiction on the ground               
          that petitioner failed to make a timely request for an                      
          administrative hearing and, therefore, respondent was not obliged           
          to (and did not) issue a determination letter to petitioner.                
                                     Background                                       
               On or about September 10, 1999, respondent mailed to                   
          petitioner a Notice Of Federal Tax Lien Filing And Your Right To            
          A Hearing Under IRC 6320 (the notice required by section 6320(a))           
          concerning petitioner’s unpaid tax liabilities for the years 1984           










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