- 11 - 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 OfficePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011