- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011