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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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Last modified: May 25, 2011