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jeopardy assessments and of petitioner’s right of appeal under
section 7429. Upon being handed the notice, petitioner refused
to accept it, whereupon respondent’s agent left the notice of the
jeopardy assessments on petitioner’s doorstep. A copy of
respondent’s notice of jeopardy assessments was also delivered by
respondent to petitioner via certified mail to the same address.
Also on June 3, 2004, based on the jeopardy assessments and
a search warrant, respondent seized $42,817 in cash from
petitioner’s office, and respondent applied the $42,817 to
petitioner’s Federal income tax for 1995, as assessed on June 1,
2004.
Petitioner requested neither administrative nor judicial
review of respondent’s jeopardy assessments.
On June 4, 2004, respondent mailed to petitioner at the
above address of petitioner a notice of Federal tax lien filing
and right to a hearing under section 6320 (Lien Notice), which
lien related to the above jeopardy assessments and which notice
explained petitioner’s right to a section 6320 hearing with
regard to the filed Federal tax lien.
Petitioner did not request a hearing with regard to the
above Lien Notice.
On July 29, 2004, respondent mailed to petitioner at
petitioner’s address a notice of deficiency with respect to
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