- 4 - D. The Appeals Office Hearing The Appeals Office concluded that petitioners’ request for an administrative hearing was timely filed in respect of the notice required by section 6320(a) but was not timely filed in respect of the notice of intent to levy. Accordingly, on October 9, 2001, the Appeals Office conducted both an administrative hearing in respect of the notice required by section 6320(a) and a so-called equivalent hearing in respect of the notice of intent to levy. See sec. 301.6330-1(c)(2)Q&A-C7, (i), Proced. & Admin. Regs. E. The Notice of Determination and the Decision Letter On January 25, 2002, the Appeals Office issued to petitioners a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330 (notice of determination). The notice of determination was issued in respect of the notice required by section 6320(a), and it reflected the conclusion of the Appeals Office that the filing of the notice of Federal tax lien was an appropriate collection action by respondent. The notice of determination also advised petitioners that they had 30 days to file a petition with the Tax Court seeking judicial review of respondent’s determination regarding the notice required by section 6320(a). Also on January 25, 2002, the Appeals Office issued to petitioners a Decision Letter Concerning Equivalent Hearing UnderPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011