Green v. Comm'r
United States Tax Court
On May 2, 2003, R made jeopardy assessments of deficiencies that R determined in P's taxes for 1995 through 1999. R also issued a notice of jeopardy levy with respect to those assessments. On May 20, 2003, P requested administrative review pursuant to sec. 7429(a)(2), I.R.C. At some point after July 16, 2003, R made a determination under sec. 7429(a)(3), I.R.C., sustaining the jeopardy assessment and jeopardy levy.
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On May 2, 2003, R made jeopardy assessments of deficiencies that R determined in P's taxes for 1995 through 1999. R also issued a notice of jeopardy levy with respect to those assessments. On May 20, 2003, P requested administrative review pursuant to sec. 7429(a)(2), I.R.C. At some point after July 16, 2003, R made a determination under sec. 7429(a)(3), I.R.C., sustaining the jeopardy assessment and jeopardy levy. On Nov. 19, 2003, we received P's motion to review the jeopardy assessment and jeopardy levy. Held: Under sec. 7429(b)(1), I.R.C., the taxpayer's proceeding for judicial review…
1Opinion of the Court
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…
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3Cited by2 opinions
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