Kalkhoven
Kalkhoven v. United States
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 10 Kevin Kalkhoven, No. 2:21-cv-01440-KJM-JDP Plaintiff, ORDER Vv. United States of America, Defendant. 16 Kevin Kalkhoven appeals the jeopardy assessment the Internal Revenue Service effected 18 against him. Presently, he moves to seal almost the entirety of the 1797-page administrative 19 record. For the reason’s below, the court denies the request to seal. 20 I. BACKGROUND On or about July 6, 2021, the Internal Revenue Service (“IRS”) initiated a jeopardy assessment against Kevin Kalkhoven. Compl. §] 1, ECF No. 1. Kalkhoven initiated this action under 26 U.S.C. § 7429, seeking judicial review of the jeopardy assessment and jeopardy levy. 24 See generally id. Kalkhoven requests to seal portions of the underlying administrative record. Notice of Request to Seal, ECF No. 6. By Kalkhoven’s own admission, some aspects of the record are public. However, he …