- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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