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decision letter does not constitute a notice of determination
under section 6330(d)(1) which would provide a basis for
petitioners to invoke the Court’s jurisdiction for 1998. See
Moorhous v. Commissioner, 116 T.C. 263, 270 (2001); Kennedy v.
Commissioner, supra at 263.
This case is distinguishable from Craig v. Commissioner, 119
T.C. 252 (2002), in which we held that we had jurisdiction under
section 6330(d)(1) when the Appeals Office issued a decision
letter to the taxpayer. Id. at 259. In Craig, the Commissioner
mailed to the taxpayer a notice of intent to levy on February 22,
2001. Id. at 254. On March 17, 2001, the taxpayer timely
requested a section 6330 hearing by mailing the Commissioner a
letter accompanied by unsigned Forms 12153. Id. at 255. On May
6, 2001, the Commissioner received signed Forms 12153 but granted
the taxpayer only an equivalent hearing. Id. at 255-256. A
decision letter was then issued to the taxpayer following the
equivalent hearing. Id. at 256. The Court held that “where
Appeals issued the decision letter to petitioner in response to
his timely request for a Hearing, we conclude that the ‘decision’
reflected in the decision letter issued to petitioner is a
‘determination’ for purposes of section 6330(d)(1).” Id. at 259.
In the instant case, petitioners did not timely request a section
6330 hearing in response to the June 23, 2000, notice. As a
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