- 11 - such a hearing within 30 days from the date of respondent’s February 5, 1999 notice of intent to levy concerning her taxable years 1994, 1995, and 1996, which notified her of her right to an Appeals Office hearing. See sec. 6330(a)(3)(B); sec. 301.6330- 1(c)(2), Q&A-C7, Proced. & Admin. Regs. Instead of an Appeals Office hearing, respondent held an equivalent hearing with respect to respondent’s February 5, 1999 notice of intent to levy concerning Ms. Holguin’s taxable years 1994, 1995, and 1996. See sec. 301.6330-1(i)(1), Proced. & Admin. Regs. Consequently, respondent issued a decision letter to Ms. Holguin instead of a notice of determination. Id. That letter was not, and did not purport to be, a determination under section 6330(d). See, e.g., Moorhous v. Commissioner, supra at 270. We conclude that we do not have jurisdiction over Ms. Holguin.12 See sec. 6330(d)(1); Moorhous v. Commissioner, supra. We shall grant respondent’s motion to dismiss for lack of juris- diction as to Ms. Holguin. 12We note that petitioners do not object to the Court’s granting respondent’s motion to dismiss for lack of jurisdiction as to Ms. Holguin.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011