Kalkhoven

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 10 Kevin Kalkhoven, No. 2:21-cv-01440-KJM-JDP Plaintiff, ORDER v. United States of America, 1S Defendant. 16 Kevin Kalkhoven appeals the jeopardy assessment the Internal Revenue Service (IRS) has 18 effected against him. Specifically, Kalkhoven asks this court to abate the jeopardy assessment 19 and the liens and levies imposed by the IRS. Having considered the parties’ briefing and arguments made at hearing, the court denies the motion as explained below. I. BACKGROUND On July 6, 2021, the IRS initiated a jeopardy assessment against Kevin Kalkhoven. Compl. 4 1, ECF No. 1. The assessment was based on a number of factors: a review of Kalkhoven’s tax returns for the last twenty years, primarily for tax years 2000 and 2001; his 25 participation in various tax shelters with substantial assets held in offshore accounts, a subject which is the subject of ongoing…