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and he did not receive it. Petitioner received an “equivalent
hearing” decision letter regarding the levy. An “equivalent
hearing” decision letter, unlike a notice of determination,
generally does not constitute a “determination” for purposes of
section 6320 or 6330 and so does not provide the requisite basis
for invoking this Court’s jurisdiction under section 6320 or
6330. See Moorhous v. Commissioner, 116 T.C. 263, 269-270
(2001); Kennedy v. Commissioner, supra; cf. Craig v.
Commissioner, 119 T.C. 252 (2002) (holding that a decision letter
issued in response to a timely request for a hearing provides the
requisite jurisdictional basis under section 6330(d)(1)).
Petitioner has not properly placed before us any request to
review the “equivalent hearing” decision letter as to the
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Last modified: November 10, 2007