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determination pursuant to section 6330 in which respondent
determined that the lien filings constituted appropriate action
and denied petitioner any relief.
As stated, respondent did not conduct a CDP hearing with
regard to the levy proposed in the Levy Letter, and respondent
did not issue a notice of determination with regard thereto.
On October 6, 2000, petitioner filed his petition herein in
which petitioner challenges both the proposed levy and the
proposed lien filings.
OPINION
Prior to collection of taxes by way of a levy on a
taxpayer’s property, section 6330 requires that respondent give
taxpayers notice of, and the opportunity for, administrative
review of the proposed levy in the form of a CDP hearing.
Section 6330(a) specifically provides that respondent shall
notify a taxpayer of the right to a CDP hearing by mailing a
notice of intent to levy to the taxpayer’s last known address,
and the taxpayer has 30 days from the mailing of that notice to
request a CDP hearing. If a timely request for a CDP hearing is
made, respondent is required to make a determination of the
issues raised at the hearing. Sec. 6330(c).
Under section 6330(d), we have jurisdiction to review
respondent’s determination with respect to issues raised at a CDP
hearing only if a notice of determination pursuant to section
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Last modified: May 25, 2011