MEMORANDUM OPINION
SWIFT, Judge:
This matter is before us under Rule 121 on the parties' cross-motions for summary judgment. The underlying issue in this so-called collection "due process" case involves the appropriateness of respondent's proposed levy action against petitioner's property arising from jeopardy assessments respondent made against petitioner.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect...
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