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Appeals officer informed petitioner's attorney that any request
for judicial review of the jeopardy assessment and jeopardy levy
had to be received by the appropriate court before September 4,
2003.
We hold that we do not have jurisdiction to review the
jeopardy assessment and jeopardy levy in this case. Petitioner's
motion to review the jeopardy assessment and jeopardy levy
therefore will be denied.
An appropriate
order will be issued.
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