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months later, petitioner filed his bankruptcy petition.
Thereafter, respondent issued to petitioner the notices of
determination that led petitioner to attempt to invoke the
Court’s jurisdiction.
Against this backdrop, we are satisfied that the issuance of
the final notices of intent to levy to petitioner constituted
administrative collection actions taken against petitioner
(before the commencement of the bankruptcy case) within the
meaning of 11 U.S.C. section 362(a)(1) (2000). Consistent with
the foregoing, it follows that the issuance to petitioner of the
notices of determination constituted the continuation of
administrative collection actions against petitioner (after the
commencement of the bankruptcy case) within the meaning of 11
U.S.C. section 362(a)(1) (2000). Our conclusion that the levy
notices and notices of determination constituted actions against
petitioner (as opposed to an action initiated by petitioner) is
bolstered by the nature and purpose of such notices. We observe
that if petitioner had failed to request an administrative
hearing within 30 days of the issuance of the final notices of
intent to levy, he would have waived his right to administrative
and judicial review of the proposed collection actions under
section 6330, and respondent normally would have been free to
proceed with the proposed levies. See Kennedy v. Commissioner,
116 T.C. 255, 262 (2001). Giving due regard to the public
policies underlying the automatic stay provisions, we conclude
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