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On May 7, 2001, respondent issued to petitioners the notice
required by section 6320(a).
On or shortly after May 11, 2001, petitioners submitted to
the Appeals Office a request for an administrative hearing in
respect of both the notice of intent to levy and the notice
required by section 6320(a). The 30-day period prescribed in
section 6330(a)(2) and (3)(B) for the filing of a timely request
for an Appeals Office hearing in respect of the notice of intent
to levy expired on Monday, March 12, 2001. See sec. 301.6330-
1(c)(2) Q&A-C3, Proced. & Admin. Regs.; see also sec. 7503.
Because petitioners’ request for an Appeals Office hearing was
not timely in respect of the notice of intent to levy, the
Appeals Office was not obliged to provide petitioners with the
administrative hearing contemplated by section 6330 in respect of
that notice. On the other hand, because petitioners’ request for
an Appeals Office hearing was timely with respect to the notice
required by section 6320(a), the Appeals Office was obliged to
provide petitioners with the administrative hearing contemplated
by section 6320 in respect of that notice. Indeed, the record
demonstrates that an administrative hearing was in fact conducted
on October 9, 2001, in respect of the notice required by section
6320(a).
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Last modified: May 25, 2011