- 6 - Respondent granted petitioners a section 6320 Appeals Office hearing relating to the NFTL. Because, however, petitioners in November of 2004 already had had an opportunity to request an Appeals Office collection hearing relating to respondent’s 2004 levy on petitioners’ California income tax refund, respondent granted to petitioners only an equivalent hearing relating to respondent’s September 7, 2005, second levy notice. On March 3, 2006, respondent’s Appeals Office mailed to petitioners a decision letter sustaining respondent’s September 7, 2005, levy notice and a notice of determination sustaining respondent’s September 8, 2005, NFTL. Discussion Generally, no appeal to this Court lies with regard to respondent’s decision letters relating to equivalent hearings. Rule 330; Kennedy v. Commissioner, 116 T.C. 255, 261-262 (2001); sec. 301.6330-1(i)(2), Q&A-I5, Proced. & Admin. Regs. The Court will dismiss sua sponte for lack of jurisdiction all issues herein relating to the Appeals Office equivalent hearing that was held and to respondent’s decision letter relating to respondent’s September 7, 2005, levy notice. Orum v. Commissioner, 123 T.C. 1, 10-12 (2004), affd. 412 F.3d 819 (7th Cir. 2005). We decide respondent’s and petitioners’ cross-motions for summary judgment only as they relate to respondent’s September 8, 2005, NFTL.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008