6. You are consulted by the court-appointed guardian of Sam Strate regarding the following situation. In 201, Sam sold a piece of property that had a basis of $35,000 for $235,000. Under the terms of the contract of sale, Sam received $35,000 in 202 with the balance of the proceeds being placed in escrow. The escrowee was to pay the remaining $200,000 out in four equal installments over the four years after the closing of the sale. However, the escrowee was given authority to pay the balance to Sam if Sam were to request accelerated payments and were to cite changed circumstances that would convince his nephew, the escrowee, that acceleration was warranted. In 20X4, Seymour Sharpeyes of the IRS examination function audited Sam's return. Sharpeyes determined that Sam was in constructive receipt of the entire sale proceeds and, therefore, disallowed the installment treatment claimed on the 202 return. He sought to tax Sam upon the entire gain in 202. At his final conference with the agent, Sam was informed that the understatement of tax would be at least $35,000. The very evening that Sam had his final conference with Sharpeyes, he happened to attend a cocktail party. He mentioned to one of the persons there that he had the conference with the IRS and his acquaintance told him about the terrible things the IRS can do. He referred to something called a jeopardy assessment, which he said the IRS can use to tie up all of his property if he does not pay the tax. Sam was very nervous about this, and a week later he became so distraught that he had a nervous breakdown and was hospitalized. Because of his stay in the hospital, all correspondence from the IRS went unanswered. Finally, a guardian was appointed to look into Sam's affairs. The guardian consults you to see whether the IRS can make a jeopardy assessment of the taxes and whether they can seize all of Sam's property on the basis of the circumstances that he has described