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Section 7429(b) provides for judicial review of a jeopardy
assessment or jeopardy levy. Typically a Federal District Court
reviews the jeopardy assessment or jeopardy levy; however, in
certain circumstances, the Tax Court is authorized to review the
reasonableness of a jeopardy assessment or jeopardy levy, as well
as the propriety of the amount of a jeopardy assessment.6 Sec.
7429(b)(2) and (3). Our authority to review jeopardy assessments
under section 7429(b)(2)(B) is limited to a jeopardy assessment
or jeopardy levy made subsequent to the filing of a petition for
redetermination under section 6213(a) and respecting one or more
of the same taxes and taxable periods disputed in such petition.
See Friko Corp. v. Commissioner, 26 F.3d 1139, 1140-1141 (D.C.
Cir. 1994). This requirement is met since petitioner's petition
for redetermination in docket No. 178-02 was filed before the
jeopardy assessment and jeopardy levy.7
6 Sec. 7429 was added to the Code by the Tax Reform Act of
1976, Pub. L. 94-455, sec. 1204(a), 90 Stat. 1695-1696. Sec.
7429 was amended to allow review of jeopardy assessments or
jeopardy levies in the Tax Court. Technical and Miscellaneous
Revenue Act of 1988, Pub. L. 100-647, sec. 6237, 102 Stat. 3741.
This change applies to jeopardy assessments or jeopardy levies
made on or after July 1, 1989. See McWilliams v. Commissioner,
103 T.C. 416, 419 n.4 (1994).
7 We note that the petition in docket No. 12108-03 for
taxable year 1999 was filed after the jeopardy assessment for
that year. Nevertheless, because the petition in docket No. 178-
02 involves taxes and taxable periods that were included in the
written statement issued to petitioner under sec. 7429(a)(1)(B),
we have jurisdiction, if otherwise appropriate, over all the
taxes and taxable periods included in that written statement,
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