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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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