Joseph W. Dorn - Page 7




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          or bars judicial review of a jeopardy levy determination; that              
          interpretation of the flush language would be at odds with the              
          overall purpose of section 6330 of providing procedural                     
          protections in collection disputes.  Thus, we conclude that we              
          have jurisdiction under section 6330(d) to review respondent’s              
          determination under section 6330(f) that use of a jeopardy levy             
          was appropriate.                                                            
               To reflect the foregoing,                                              
                                                       An appropriate order           
                                                  will be issued.                     































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