121 T.C. No. 18 UNITED STATES TAX COURT GEORGE G. GREEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 178-02. Filed December 8, 2003. On May 2, 2003, R made jeopardy assessments of deficiencies that R determined in P's taxes for 1995 through 1999. R also issued a notice of jeopardy levy with respect to those assessments. On May 20, 2003, P requested administrative review pursuant to sec. 7429(a)(2), I.R.C. At some point after July 16, 2003, R made a determination under sec. 7429(a)(3), I.R.C., sustaining the jeopardy assessment and jeopardy levy. On Nov. 19, 2003, we received P's motion to review the jeopardy assessment and jeopardy levy. Held: Under sec. 7429(b)(1), I.R.C., the taxpayer's proceeding for judicial review must be commenced within 90 days after the earlier of the day the Commissioner notifies the taxpayer of the Commissioner's determination under sec. 7429(a)(3), I.R.C., or the 16th day after the request for review under sec. 7429(a)(2), I.R.C., was made. P's motion for review of the jeopardy assessment and jeopardy levy was not timely filed under sec. 7429(b)(1), I.R.C.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011