- 5 - that the decision letter should be treated as a notice of determination with respect to which judicial review of the underlying tax deficiency might have been available.1 On November 4, 2004, respondent filed a notice of Federal tax lien (NFTL) relating to the $24,629 tax deficiency against petitioner for 1996 that respondent had assessed. On November 5, 2004, respondent mailed to petitioner at petitioner’s current address a section 6320 lien notice relating to the above NFTL, in which respondent indicated a December 13, 2004, deadline for receipt from petitioner of a section 6320 Appeals Office hearing request. In response to respondent’s November 5, 2004, lien notice, on December 8, 2004, petitioner mailed to respondent by overnight mail a request for an Appeals Office hearing. On December 9, 2004, respondent received petitioner’s above request. From January to October 2005, in connection with respondent’s November 4, 2004, NFTL, respondent held an Appeals 1Arguably, if respondent’s Nov. 16, 1999, levy notice was not mailed to petitioner’s last known address, petitioner’s July 8, 2002, request for an Appeals Office hearing should have been treated as timely, and a regular sec. 6330 Appeals Office hearing should have been held, not an equivalent hearing. See sec. 301.6330-1(i), Proced. & Admin. Regs. (explaining when an equivalent hearing is to be held). In Craig v. Commissioner, 119 T.C. 252 (2002), we treated a decision letter from an equivalent hearing, which should have been treated as a regular sec. 6330 hearing, as a notice of determination for purposes of allowing our review of respondent’s Appeals Office determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007