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or her last known address.
Section 6330(a)(2) provides that the prescribed notice shall
be provided not less than 30 days before the day of the first
levy with respect to the amount of the unpaid tax for the taxable
period. Further, section 6330(a)(3)(B) provides that the
prescribed notice shall explain that the person has the right to
request an Appeals Office hearing during the 30-day period under
paragraph (2).
Where the Appeals Office issues a notice of determination to
the taxpayer following an administrative hearing regarding a levy
action, section 6330(d)(1) provides that the taxpayer will have
30 days following the issuance of such determination letter to
file a petition for review with the Tax Court or Federal District
Court, as may be appropriate. See Offiler v. Commissioner, 114
T.C. 492, 498 (2000). We have held that the Court’s jurisdiction
under section 6330 depends on the issuance of a valid
determination letter 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.
On October 13, 2000, respondent mailed to petitioner a final
notice of intent to levy with regard to his unpaid taxes for
1993, 1994, 1995, and 1996. Petitioner received the final notice
of intent to levy on October 14, 2000. Consequently, the 30-day
period within which petitioner was required to file with
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