-13-
authorize the Commissioner to lengthen or shorten the 30-day
period for requesting a section 6330 hearing. Moorhous v.
Commissioner, 116 T.C. 263, 270 n.5 (2001); Kennedy v.
Commissioner, supra at 262.
In this case, because petitioners did not timely request a
section 6330 hearing, petitioners were not entitled to such a
hearing and were not offered one. Consequently, we shall grant
respondent’s deemed motion for summary judgment.
IV. Conclusion
Although we deny respondent’s motion insofar as it asks us
to dismiss this case for lack of jurisdiction, it is clear that
petitioners are not entitled to relief under section 6330. We
have treated respondent’s motion as a motion for summary
judgment, and we shall grant respondent’s motion because
petitioners did not timely request a section 6330 hearing.
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011