Paul Everman - Page 11

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          T.C. 492, 498 (2000).  We have held that this Court’s                       
          jurisdiction under sections 6320 and 6330 depends on the issuance           
          of a valid notice of determination and the filing of a timely               
          petition for review.  See Sarrell v. Commissioner, 117 T.C. 122,            
          125 (2001); Offiler v. Commissioner, supra at 498.                          
               The record shows that respondent sent petitioner (1) a                 
          notice required by section 6320 on March 9, 2001, and (2) a final           
          notice of intent to levy on May 7, 2001.  However, petitioner did           
          not file his request for an administrative hearing with                     
          respondent until June 18, 2001.  After concluding that petitioner           
          had failed to file his request for an administrative hearing                
          within the 30-day period prescribed in section 6330(a)(2) and               
          (a)(3)(B), the Appeals officer informed petitioner that                     
          petitioner would be offered an equivalent hearing as opposed to             
          the administrative hearing contemplated by section 6330.  See               
          Craig v. Commissioner, 119 T.C. 252, 258 (2002) (describing the             
          genesis for equivalent hearings).  Following the hearing, the               
          Appeals Office issued to petitioner a decision letter stating               
          that the proposed collection actions were appropriate.                      
               Respondent cites Kennedy v. Commissioner, 116 T.C. 255                 
          (2001), in support of his motion to dismiss that part of the                
          petition challenging the decision letter dated July 12, 2002.  In           
          Kennedy v. Commissioner, supra, we held, under similar                      
          circumstances, that a decision letter issued by an Appeals Office           






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