Frank Lopez - Page 8




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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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