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[*16] The District Court subsequently issued forfeiture orders as to petitioner and Mr. Hovind. Under the forfeiture orders, petitioner and Mr. Hovind were liable individually and jointly in the amount of $430,400. On June 27, 2007, the court entered its first Order Forfeiting Substitute Property against petitioner and Mr. Hovind, which forfeited petitioner’s and Mr. Hovind’s interests in account 8577 and 10 properties. On October 8, 2008, the court entered its second Order Forfeiting Substitute Property, which forfeited petitioner’s and Mr. Hovind’s interests in account 1872.

VIII.

In 2007 respondent began an examination in respect of petitioner and Mr. Hovind. IRS Revenue Agent AlyceFaye was assigned to petitioner’s case. Revenue Agent AlyceFaye mailed petitioner a letter requesting that petitioner ___________