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We sustain respondent’s collection actions regarding 1990,
1991, and 1992. When the Commissioner determines that a taxpayer
has a deficiency in tax, he is authorized to send a notice of
that deficiency to the taxpayer. Sec. 6212. Section 6213(a)
generally restricts when the Commissioner may assess a
deficiency, make a levy determination, and begin or prosecute a
collection action in a court proceeding. The Commissioner is
generally prohibited from taking these actions until: (1) The
notice of deficiency has been mailed to the taxpayer; (2) the 90-
day period in which the taxpayer may petition the Tax Court has
expired; and (3) if a petition has been filed with the Tax Court,
the Tax Court’s decision becomes final. Sec. 6213(a).
Section 6861 provides an exception to the restrictions on
assessment and collection of deficiencies imposed by section
6213(a). Section 6861(a) provides that the Commissioner may
immediately assess the deficiency when he believes that the
assessment or collection of a deficiency will be jeopardized by
delay. “A jeopardy assessment may be made before or after the
mailing of the notice of deficiency provided by section 6212.”
Sec. 301.6861-1(a), Proced. & Admin. Regs. The Commissioner may
make a jeopardy assessment or collection when the taxpayer is or
appears to be: (1) Planning to depart from the United States, or
conceal himself or herself; (2) planning to place his property
beyond the reach of Commissioner by concealing it, by dissipating
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