Michael A. Zapara and Gina A. Zapara - Page 20

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         jeopardy.  Sec. 6331(d)(3).  Because respondent made a jeopardy              
         finding in this case, we conclude that respondent has complied               
         with section 6331(d) and that the 30-day period described in that            
         section is inapplicable.                                                     
         V.  Failure To Sell Stock Accounts                                           
              Respondent served a notice of levy, dated June 1, 2000, on              
         Travis Morgan Securities, Inc., which held a number of stock                 
         accounts that Mr. Zapara owned.  Petitioners allege that, at the             
         time of the levy, the stock accounts had a value of approximately            
         $1 million.  Petitioners contend that they requested respondent              
         to liquidate the stock accounts, but that respondent failed to               
         honor their request.  Petitioners claim the stocks have since                
         suffered a significant decline in value.  Petitioners argue that             
         they should be given full credit of $1 million for the stock                 
         accounts.                                                                    
              A.  Seizure and Sale of Property                                        
              The Code defines the term “levy” to include seizure by any              
         means.  Sec. 6331(b).  Levy may be made by serving a notice of               
         levy on any person in possession of, or obligated with respect               
         to, property or rights to property subject to levy, including                
         receivables, bank accounts, evidences of debt, securities, and               
         salaries, wages, commissions, or other compensation.  Sec.                   
         301.6331-1(a)(1), Proced. & Admin. Regs.  A levy is effective                







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