Michael Craig v. Commissioner - Page 1

                                   119 T.C. No. 15                                    

                               UNITED STATES TAX COURT                                

                            MICHAEL CRAIG, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14649-01L.            Filed November 14, 2002.              

                    On Feb. 22, 2001, R mailed to P a final notice of                 
               intent to levy (final notice) for 1990, 1991, and 1992.                
               On the same day, R mailed to P a final notice for 1995.                
               On March 17, 2001, P timely requested a hearing under                  
               sec. 6330, I.R.C. (Hearing), as to both final notices.                 
               Subsequently, R’s Appeals officer (A) held with P an                   
               “equivalent hearing” under sec. 301.6330-1(i), Proced.                 
               & Admin. Regs.  A informed P at the equivalent hearing                 
               that P was not allowed a Hearing because, A mistakenly                 
               believed, P’s request for a Hearing was untimely.  A                   
               later issued to P a decision letter sustaining the                     
               proposed levy.                                                         
               Held:  The determination reflected in the decision                     
               letter, coupled with P’s timely petition to this Court                 
               with respect thereto, serves to invoke this Court’s                    
               jurisdiction under sec. 6330(d)(1), I.R.C.                             

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