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determination in the form of a notice of determination setting
forth its findings and decisions. Sec. 301.6330-1(e)(3), Q&A-E8,
Proced. & Admin. Regs. When Appeals issues the notice of
determination, the taxpayer has 30 days following the issuance to
file a petition for review of the determination with this Court
or a Federal District Court, as may be appropriate. Sec.
6330(d)(1).
A taxpayer who fails to timely request a section 6330
hearing is not entitled to a section 6330 hearing but may
nevertheless request an administrative hearing with Appeals that
is referred to as an “equivalent hearing”. Sec. 301.6330-
1(i)(1), Proced. & Admin. Regs.; see also sec. 301.6330-1(c)(2),
Q&A-C7, Proced. & Admin. Regs. The equivalent hearing generally
follows Appeals’s procedures for a section 6330 hearing, and
Appeals will consider the same issues it would have considered at
a section 6330 hearing on the same matter. Sec. 301.6330-1(i)(1)
and (2), Q&A-I1, Proced. & Admin. Regs. Rather than issue a
notice of determination after an equivalent hearing, however,
Appeals will issue a decision letter. Sec. 301.6330-1(i)(1),
Proced. & Admin. Regs. A decision letter generally contains the
same information required to be in a notice of determination,
except that it ordinarily states in regard to most issues that a
taxpayer may not seek judicial review of the decision. Craig v.
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Last modified: May 25, 2011