Ronald W. Nelson, Jr. and Jennifer J. Nelson - Page 4




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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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