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result, we do not conclude that the decision in the decision
letter is a determination for purposes of section 6330(d)(1).
We will grant respondent’s motion to dismiss for lack of
jurisdiction as to 1998 because the petition was not filed in
response to a notice of determination sufficient to confer
jurisdiction on the Court under section 6330(d)(1).
II. Respondent’s Determination for 1999
Petitioners argue that respondent abused his discretion in
the determination to sustain the proposed collection action for
1999 because respondent refused to process petitioners’ offer-in-
compromise and rejected petitioners’ request for an installment
agreement.
As discussed above, before a levy may be made on any
property or right to property, a taxpayer is entitled to notice
of intent to levy and notice of the right to a fair hearing
before an impartial officer of the Appeals Office. Secs. 6330(a)
and (b) and 6331(d). If the taxpayer requests a section 6330
hearing, he may raise in that hearing any relevant issue relating
to the unpaid tax or the proposed levy, including challenges to
the appropriateness of the collection action and “offers of
collection alternatives, which may include the posting of a bond,
the substitution of other assets, an installment agreement, or an
offer-in-compromise.” Sec. 6330(c)(2)(A). A determination is
then made which takes into consideration those issues, the
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