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that provision. We consider respondent to have initiated a
collection action against petitioner for purposes of section 6330
when respondent notified petitioner that respondent was intending
to levy upon petitioner’s property. We do not consider
respondent’s filing of the liens upon the property as the
initiation of that collection action so as to preclude review
under section 6330.
On the basis of our conclusion that respondent initiated a
collection action for purposes of section 6330 when he issued to
petitioner the notice of intent to levy, we hold that we have
jurisdiction to decide this case. Accordingly,
An order will be issued
denying respondent’s motion.
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Last modified: May 25, 2011