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following an equivalent hearing did not constitute a notice of
determination under section 6330(d), and, therefore, the decision
letter did not provide a basis for the taxpayer to invoke this
Court’s jurisdiction. See Moorhous v. Commissioner, 116 T.C.
263, 270-271 (2001).
Petitioner concedes in his petition that his request for an
administrative hearing was not filed with respondent within the
30-day period prescribed in section 6330(a). Petitioner
nevertheless contends that the Appeals Office erred in conducting
an equivalent hearing, as opposed to an administrative hearing
under section 6330, on the ground the final notice of intent to
levy was invalid because it was not signed by the Secretary or an
authorized delegate. We disagree.
It is well settled that the Secretary or his delegate
(including the Commissioner) may issue a notice required by
section 6320 or a final notice of intent to levy. Secs. 6320(a),
6330(a), 7701(a)(11)(B) and (12)(A)(i), 7803(a)(2); see Craig v.
Commissioner, 119 T.C. 252, 263 (2002); Wilson v. Commissioner,
T.C. Memo. 2002-242; secs. 301.6320-1(a)(1), 301.6330-1(a)(1),
301.7701-9, Proced. & Admin. Regs. The Commissioner’s authority
to file a notice of Federal tax lien and/or issue a final notice
of intent to levy has been delegated to a host of Internal
Revenue Service personnel, including (in the case of Federal tax
liens) various managers responsible for collection matters and
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