George G. Green - Page 2

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               George G. Green, pro se.                                               
               Gerald L. Brantley and Bruce M. Wilpon, for respondent.                


                                       OPINION                                        

               THORNTON, Judge:  This matter is before us on petitioner's             
          motion for review of jeopardy assessment and jeopardy levy under            
          section 7429, filed November 19, 2003, pursuant to Rule 56.1  On            
          November 26, 2003, respondent filed a response in opposition to             
          petitioner's motion requesting that we dismiss petitioners'                 
          motion as untimely.                                                         
                                     Background                                       
               On August 10, 2001, respondent issued to petitioner a notice           
          of deficiency for petitioner's 1995, 1996, 1997, and 1998 taxable           
          years.  On January 2, 2002, petitioner filed a petition (docket             
          No. 178-02) with respect to the deficiencies for those taxable              
          years.2  On May 2, 2003, jeopardy assessments of deficiencies               
          were made against petitioner for taxable years 1995, 1996, 1997,            
          1998, and 1999, as follows:                                                 
                                                                                     


               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code as amended, and Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  
               2 On May 1, 2003, respondent issued to petitioner a notice             
          of deficiency for petitioner's 1999 taxable year.  On July 25,              
          2003, petitioner filed a petition (docket No. 12108-03) with                
          respect to the deficiency for the 1999 taxable year.                        




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