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subject to the Federal tax lien and who thereafter held the
proceeds in their personal brokerage account. However, on a
collection information statement received by respondent on
January 14, 2000, petitioner did not respond to the question of
whether assets had recently been sold or otherwise transferred
for less than their full value. On January 30, 2002, Mr. Burke
provided Settlement Officer O’Shea with a copy of another
collection information statement, signed by petitioner on January
24, 2002, on which petitioner responded “no” to the question of
whether petitioner had transferred any assets out of his name for
less than their actual value in the last 10 years. Furthermore,
during the initial section 6330 hearing, petitioner failed to
provide documents requested by Appeals Officer Kaplan relating to
the whereabouts of the 1997 bankruptcy sale proceeds.
Petitioner appears to have been designing to quickly place
the 1997 bankruptcy sale proceeds beyond the reach of the
Government by transferring such proceeds to third parties, who
might have dissipated the funds absent an immediate collection
action. Based on the administrative record in the instant case,
we conclude that respondent’s Appeals officer did not abuse her
discretion in sustaining the jeopardy levy against petitioner.
D. Whether the Parties Completed a Global Settlement Agreement.
Petitioner contends that respondent set forth a global
settlement offer pursuant to the terms of Attorney Cardone’s
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