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On August 28, 2006, 94 days after the order of dismissal was
entered, the Court filed the first mentioned document as a
“Motion for Leave to File Motion to Vacate Order of Dismissal for
Lack of Jurisdiction” (motion for leave). The Court received
petitioner’s amended petition with attached copy of the decision
letter concurrently with the motion for leave and the motion to
vacate.
Paragraph 2 of the amended petition states:
2. Petitioner(s) disagree(s) with the
determination contained in the notice issued by the
Internal Revenue Service for the year(s) or period(s)
1995, 1996 & 1997, as set forth in such notice,
DECISION LETTER CONCERNING EQUIVALENT HEARING UNDER
SECTION 6320 AND/OR 6330, dated 01/05/06 A COPY OF
WHICH ATTACHED [sic]. DO NOT ATTACH ANY OTHER DOCUMENTS
TO THIS PETITION.
The attached decision letter states in relevant part:
Dear Ms. McClelland Cowan:
We have reviewed the proposed collection action for the
period(s) shown above. This letter is our decision on
your case. A summary of our decision is stated below
and the enclosed statement shows, in detail, the
matters we considered at your Appeals hearing and our
conclusions.
Your due process hearing request was not filed within
the time prescribed under Section 6320 and/or 6330.
However, you received a hearing equivalent to a due
process hearing except that there is no right to
dispute a decision by the Appeals Office in court under
IRC Sections 6320 and/or 6330.
Your case will be returned to the originating IRS
office for action consistent with the decision
summarized below and described on the attached page(s).
* * * * * * *
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Last modified: May 25, 2011