George G. Green - Page 1

                                   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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