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filing petition); Grama v. Commissioner, T.C. Memo. 1985-608
(“even if the Commissioner himself had given petitioners a
written agreement purporting to extend the time within which to
file a petition, he has no authority to do so”).
Under the circumstances, the Appeals Office was not obliged
to conduct an administrative hearing as contemplated under
section 6330(b). In lieu of an Appeals Office hearing under
section 6330(b), the Appeals Office granted petitioner a so-
called equivalent hearing. Thereafter, the Appeals Office issued
a decision letter to petitioner stating that respondent would
proceed with collection. The decision letter does not constitute
a notice of determination under section 6330(d), and it does not
provide a basis for petitioner to invoke the Court’s
jurisdiction. See Kennedy v. Commissioner, supra at 263; see
also Moorhous v. Commissioner, 116 T.C. 263, 270 (2001); cf.
Craig v. Commissioner, 119 T.C. 252, 258-259 (2002).
Consistent with the preceding discussion, we hold that the
petition in this case was not filed in response to a notice of
determination sufficient to confer jurisdiction on the Court
under section 6330. Accordingly, we shall grant respondent’s
motion to dismiss, as supplemented.
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