Joseph W. Dorn - Page 1

                                   119 T.C. No. 22                                    

                               UNITED STATES TAX COURT                                

                            JOSEPH W. DORN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6240-00L.              Filed December 30, 2002.             

                    To collect petitioner’s (P) unpaid income tax                     
               liabilities for 1987-89, respondent (R) issued a notice                
               of levy to a fund in which petitioner maintained                       
               accounts and issued to P a notice of jeopardy levy and                 
               right to appeal.  See sec. 6330(f), I.R.C.  P requested                
               and R held a hearing under sec. 6330(b), I.R.C.  After                 
               the hearing, R determined that imposition of a jeopardy                
               levy was appropriate.  P filed a petition under sec.                   
               6330(d), I.R.C., seeking judicial review of that                       
                    Held:  The Tax Court has jurisdiction under sec.                  
               6330(d), I.R.C., to review R’s determination that R’s                  
               use of a jeopardy levy was appropriate.                                

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