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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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