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entitled, for purposes of the address to which the notice of levy
would be mailed, to use petitioner’s Desert Inn address. With
respect to the levy proposed in the Levy Letter, respondent gave
petitioner under section 6330 adequate notice of and the
opportunity to request a CDP hearing.
Petitioner failed timely to request a CDP hearing, and
petitioner is not now entitled to challenge in this Court
respondent’s failure to grant petitioner a CDP hearing with
regard to the proposed levy.
Further, because respondent did not issue to petitioner a
notice of determination with regard to the proposed levy and
because respondent’s decision letter pursuant to the equivalent
hearing does not constitute a notice of determination under
section 6330, we lack jurisdiction to review respondent’s
proposed levy.
To reflect the foregoing,
An appropriate order of
dismissal for lack of
jurisdiction as to the
proposed levy relating to
petitioner’s property for
unpaid Federal income tax for
1984 through 1987, 1991
through 1993, and 1996, will
be issued.
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Last modified: May 25, 2011