- 8 - (notice of determination) for the lien filed August 12, 2002. The notice of determination stated that, because petitioner had a prior opportunity to dispute his underlying tax liabilities for the years 1990 through 1993, he was precluded from contesting those liabilities in the hearing for the lien filing. The Greensboro office also issued to petitioner a “DECISION LETTER CONCERNING EQUIVALENT HEARING UNDER SECTION 6320 and/or 6330 of the Internal Revenue Code” for the notice of levy dated December 29, 2000. On May 27, 2003, petitioner filed the petition and attached to it the decision letter and the notice of determination. On April 28, 2004, respondent filed a motion to dismiss for lack of jurisdiction on the ground that no notice of determination under section 6330 was sent to petitioner for the years 1990 through 1993. On January 13, 2005, this Court granted respondent’s motion to dismiss on the ground that the levy notice sent to petitioner on December 29, 2000, was not sent to petitioner’s last known address and was invalid and that no notice of determination was sent to petitioner for the levy notice dated December 29, 2000. On March 30, 2005, respondent filed a motion to remand this case to respondent’s Appeals Office for consideration of the underlying tax liabilities and the issuance of a supplemental notice of determination addressingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007