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District Court entered an order declining to take any action in
response to the letter submitted by Michael Hoover and Tadd
Hoover.
Collection Actions
On June 28, 1999, respondent made a jeopardy assessment of
petitioner’s deficiencies, and penalties for 1989, 1990, 1991,
and 1992. On that same date, respondent sent to petitioner a
Notice of Jeopardy Levy and Right of Appeal, which stated:
I am notifying you that I have found that you have
consistently attempted to conceal your reportable
income and assets through the use of nominees, thereby
putting our collection of the income tax you owe for
the tax period(s) in jeopardy. Therefore, * * * I have
approved the issuance of a levy to collect the amount
your [sic] owe, although we have not provided you a
notice of intent to levy and/or notice of your right to
a hearing, generally required by Sections 6330 and 6331
* * *
Respondent’s notice of jeopardy levy and right to appeal informed
petitioner that he was entitled to request (1) an administrative
review under section 7429 and (2) a collection due process
hearing pursuant to section 6330.
Two days later, respondent sent a letter to petitioner
informing him that respondent had made a jeopardy assessment
pursuant to section 6861 regarding petitioner’s tax years 1989,
1990, 1991, and 1992. The letter notified petitioner that
respondent has “found you [petitioner] consistently attempted to
conceal your reportable income and assets through the use of
nominees, thereby tending to prejudice or render ineffectual
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