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determination under section 6330(f) that use of a jeopardy levy
was appropriate. Dorn v. Commissioner, 119 T.C. 356, 359 (2002).
Petitioner argues that the Court of Appeals for the Seventh
Circuit held that respondent may not levy on his U.S. savings
bonds. We disagree. In United States v. Hoover, 175 F.3d at
569, the court found that the U.S. District Court exceeded its
authority by ordering petitioner to surrender U.S. savings bonds
to pay his tax liability because “the Victim and Witness
Protection Act * * * does not authorize restitution for Title 26
tax offenses.” The Court of Appeals did not address whether
respondent could make a jeopardy assessment and levy pursuant to
sections 6330(f) and 6331(a); the court only addressed the U.S.
District Court’s authority under the Victim and Witness
Protection Act.
Petitioner argues that respondent abused his discretion in
determining that the collection of petitioner’s deficiencies,
interest, and penalties was in jeopardy. Again, we disagree with
petitioner. Section 301.6861-1(a), Proced. & Admin. Regs., and
section 1.6851-1(a)(1)(ii), Income Tax Regs., specifically
provide that collection is in jeopardy when a taxpayer attempts
to place assets beyond the Commissioner’s reach by transferring
the assets to another person. In petitioner’s criminal
proceeding, the U.S. District Court ordered petitioner to take
all steps necessary to turn over to the United States 304 U.S.
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