- 17 - respondent sent him a final notice of intent to levy and right to a hearing for taxable years 1995 and 1999. Petitioner argues that he never received the April 22, 2003, notice, because it was sent to his accountants’ Idaho address “which was not, and never had been, the petitioner’s address.” Thus, petitioner argues, the final notice of intent to levy was invalid and offered him no prior opportunity to contest his underlying liability. For the reasons discussed below, we agree with petitioner. 2. Petitioner’s Last Known Address Section 6330(a)(1) requires that, before making a levy, the Secretary notify the taxpayer in writing of the right to a hearing. Section 6330(a)(2) provides three options for the time and method of such a notice. The notice must be either: (1) Given in person; (2) left at the taxpayer’s dwelling or usual place of business; or (3) sent by certified or registered mail, return receipt requested, to the taxpayer’s last known address. Sec. 6330(a)(2). Regulations under sections 6330 and 6331 cross-reference section 301.6212-2, Proced. & Admin. Regs., to define “last known address”. Secs. 301.6330-1(a)(1), 301.6331-2(a)(1), Proced. & Admin. Regs. As a general rule, a taxpayer’s last known address is “the address that appears on the taxpayer’s most recently filed and properly processed Federal tax return, unless the Internal Revenue Service (IRS) is given clear and concisePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007