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savings bonds with face values of $1,000 each. Petitioner failed
to comply with the District Court’s order and transferred 150 of
those bonds to his son Michael Hoover. Because petitioner had
fraudulently attempted to evade his tax liability and had
previously attempted to transfer his assets to his son in an
attempt to elude a court order, we hold that respondent did not
abuse his discretion when he concluded that the collection of
taxes, interest, and penalties petitioner owed was in jeopardy.
VII. Conclusion
The assessment of the determined deficiency for 1989 is
barred by the 3-year statute of limitations. Petitioner
fraudulently understated his taxable income on his returns for
1990, 1991, and 1992 and is liable for fraud penalties pursuant
to section 6663. Section 6501(c), the fraud exception to the
normal 3-year statute of limitations, applies so that the
assessments for 1990, 1991, and 1992 are not barred by the
statute of limitations. The determination to uphold the jeopardy
levy and the notice of Federal tax lien for the 1990, 1991, and
1992 tax liabilities was not an abuse of discretion.
Decision will be entered under Rule
155 in docket No. 15557-99, and an
appropriate decision will be
entered in docket No. 4590-00L.
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