George G. Green v. Commissioner

121 T.C. No. 18

UNITED STATES TAX COURT GEORGE G. GREEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 178-02. Filed December 8, 2003. 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…