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.
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