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David M. Berman and Paul F. Berman, for petitioner.
Timothy R. Maher, for respondent.
COLVIN, Judge: Petitioner filed the petition in this case
under section 6330(d) seeking our review of respondent’s
determination that use of a jeopardy levy was appropriate. The
sole issue for decision in this Opinion is whether the Tax Court
has jurisdiction to review respondent’s determination that a
jeopardy levy was appropriate. We hold that we do.
Section references are to the Internal Revenue Code as
amended.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Naples, Florida, when he filed his
petition.
Petitioner maintained various accounts in a fund known as
Evergreen Funds (not otherwise identified in the record). On
November 29, 1999, respondent issued a notice of levy to
Evergreen Funds in an effort to collect petitioner’s unpaid
income tax liabilities for 1987-89. Also on that day, respondent
issued a notice of jeopardy levy and right of appeal to
petitioner relating to those tax liabilities.
Petitioner filed a timely Form 12153, Request for a
Collection Due Process Hearing. On May 1, 2000, respondent’s
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