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On April 26, 2006, respondent issued to petitioner a Final
Notice of Intent To Levy and Notice of Your Right to a Hearing
for 1991 through 1997 and 2002, and on May 11, 2006, respondent
issued to petitioner a Final Notice of Intent to Levy and Notice
of Your Right to a Hearing for 1998. Respondent also issued to
petitioner a Notice of Federal Tax Lien Filing and Your Right to
a Hearing Under IRC 6320. Petitioner timely requested a hearing
under section 6330 regarding the proposed levy. Petitioner did
not timely request a hearing under section 6320 in response to
respondent’s notice of lien filing. Respondent, however, offered
petitioner an equivalent hearing under section 301.6320-1(i),
Proced. & Admin. Regs.,2 with regard to the notice of tax lien
filing.
On June 27, 2006, Appeals Settlement Officer Michael Smith
(Settlement Officer Smith) mailed petitioner a letter
acknowledging receipt of petitioner’s request for a hearing under
section 6330. In the letter, Settlement Officer Smith scheduled
a telephone conference with petitioner to discuss petitioner’s
2A taxpayer who makes an untimely request for a sec. 6320
hearing is not entitled to a sec. 6320 hearing but may
nevertheless request an “equivalent hearing” with Appeals. Sec.
301.6320-1(i)(1), Proced. & Admin. Regs. The equivalent hearing
generally follows Appeals’ procedures for a sec. 6320 hearing,
and Appeals will consider the same issues it would have
considered at a sec. 6320 hearing on the same matter. Sec.
301.6320-1(i)(1) and (2), Q&A-I1, Proced. & Admin. Regs. Rather
than issue a notice of determination after an equivalent hearing,
however, Appeals will issue a decision letter. Sec. 301.6320-
1(i)(1), Proced. & Admin. Regs.
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Last modified: November 10, 2007