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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 Under
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