Investment Research Associates, Inc. - Page 14

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               F.  Conclusion                                                         
               There is no dispute that, although petitioner received                 
          notice of the lien that respondent filed in Florida in October              
          2002, petitioner did not submit to respondent a request for an              
          administrative hearing.  Consistent with section 301.6320-1(b)(1)           
          and (2), Proced. & Admin. Regs., respondent’s Appeals Office was            
          not obliged to (and did not) provide petitioner with an                     
          administrative hearing under section 6320 when petitioner                   
          subsequently sought to challenge the Illinois lien filed in                 
          February 2003.  See Prakasam v. Commissioner, T.C. Memo. 2006-53.           
          It is well settled that respondent may not waive the statutory              
          period in which a taxpayer must request an administrative hearing           
          under sections 6320 and 6330.  See Kennedy v. Commissioner, 116             
          T.C. 255, 262 (2001).  The Appeals Office conducted an equivalent           
          hearing and issued to petitioner a decision letter.  The decision           
          letter in question does not constitute a notice of determination            
          that would permit petitioner to invoke the Court’s jurisdiction             
          under section 6320.  See, e.g., id. at 263.  Accordingly, we are            
          obliged to dismiss this case for lack of jurisdiction.                      
               To reflect the foregoing,                                              
                                             An Order of Dismissal for                
                                        Lack of Jurisdiction will be                  
                                        entered.                                      







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