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notice of determination for 1999 which concluded that
the proposed collection activities would be sustained.
Ps filed a petition to dispute the decision letter
and the notice of determination. R filed a motion to
dismiss for lack of jurisdiction with respect to 1998.
1. Held: The June 23, 2000, notice of intent to
levy was sent to the last known address of Ps.
2. Held, further, R’s motion to dismiss for lack
of jurisdiction is granted. Ps did not file a sec.
6330, I.R.C., hearing request within 30 days of the
June 23, 2000, notice of intent to levy. See sec.
6330(a)(3), I.R.C. The Dec. 14, 2001, notice of intent
to levy did not entitle petitioners to a sec. 6330,
I.R.C., hearing. Sec. 301.6330-1(b)(2), Q&A-B2, Q&A-
B4, Proced. & Admin. Regs. The decision letter
subsequently issued does not provide a basis for the
Court’s jurisdiction under sec. 6330(d)(1), I.R.C. See
Moorhous v. Commissioner, 116 T.C. 263, 270 (2001);
Kennedy v. Commissioner, 116 T.C. 255, 262 (2001).
3. Held, further, R did not abuse his discretion
in issuing the notice of determination for 1999, and
the proposed collection action is sustained.
Keith Orum, pro se.
Sean R. Gannon, for respondent.
OPINION
HAINES, Judge: Respondent sent petitioner Keith Orum (Mr.
Orum) and petitioner Cherie Orum (Mrs. Orum) a Decision Letter
Concerning Equivalent Hearing Under Section 6320 and/or 6330
(decision letter) for 1998 and a Notice of Determination
Concerning Collection Action(s) Under Section 6320 and/or 6330
(notice of determination) for 1999.
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