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At the hearing on respondent’s motion, petitioner stated:
“Basically, the only thing I have before the Court, and the only
thing that’s--as far as I’m concerned, is the default I have
against them [the Internal Revenue Service] for not answering my
First Amendment complaint.” Petitioner further stated: “What
I’m saying is they [the Internal Revenue Service] don’t have
jurisdiction to issue anything to me. I’m not under their
jurisdiction”.
Discussion
I. Decision Letter
A decision letter is not a determination letter pursuant to
section 6320 or 6330. See Kennedy v. Commissioner, 116 T.C. 255,
263 (2001); Offiler v. Commissioner, 114 T.C. 492, 495 (2000).
Respondent did not issue a determination letter to petitioner
sufficient to invoke the Court’s jurisdiction to review the
notice of intent to levy for 2001. Kennedy v. Commissioner,
supra. Insofar as the petition filed herein purports to be a
petition for review pursuant to section 6330(d) of the notice of
intent to levy for 2001, we shall dismiss the petition as to the
notice of intent to levy for 2001 for lack of jurisdiction on the
ground that respondent did not make a determination pursuant to
section 6330 regarding the notice of intent to levy for 2001
because petitioner failed to file a timely request for an Appeals
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Last modified: May 25, 2011