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
GEORGE G. GREEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Green v. Comm'r
No. 178-02
United States Tax Court
121 T.C. 301; 2003 U.S. Tax Ct. LEXIS 39; 121 T.C. No. 18;
December 8, 2003, Filed
Petitioner's motion to review jeopardy assessment and jeopardy levy denied.
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…
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