ANDERSON, Circuit Judge.
In this appeal, we examine the propriety of a termination assessment and subsequent notice of deficiency issued pursuant to the jeopardy presumptions of § 6867 of the Internal Revenue Code ("Code") to Albert Matut in his capacity as possessor of $175,000 cash. We conclude that the assessment and notice were proper and thus we vacate the decision below and remand this case to the Tax Court with instructions to enter a deficiency judgment...
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