- 20 - 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 effectivePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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