- 33 - 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 thePage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007