{"id":1297,"date":"2022-04-12T22:47:31","date_gmt":"2022-04-12T22:47:31","guid":{"rendered":"https:\/\/sacramentotaxlawyers.com\/?p=1297"},"modified":"2022-07-06T19:19:59","modified_gmt":"2022-07-06T19:19:59","slug":"judicial-review-jeopardy-termination-assessment","status":"publish","type":"post","link":"https:\/\/sacramentotaxlawyers.com\/judicial-review-jeopardy-termination-assessment\/","title":{"rendered":"Judicial Review of Jeopardy and Termination Assessments"},"content":{"rendered":"\n

The shortcut assessment procedures for tax collections deemed to be in “danger” include jeopardy and termination assessments.  <\/p>\n\n\n\n

All the relevant provisions of the Internal Revenue Code (IRC) authorizing jeopardy and termination assessments seem favorably skewed towards the IRS and unfavorably toward the taxpayer. For instance, in regular deficiency assessments<\/a>, taxpayers are afforded the opportunity to challenge the assessment after receipt of a notice of assessment, and then again upon receipt of a notice of deficiency, before any assessment is even made. <\/p>\n\n\n\n

For jeopardy and termination assessments, however, the statutory notice of deficiency may be issued to the individual after <\/em>the assessment has been completed. This is in addition to a sufficient “written statement” containing information upon which the assessment is based.  <\/p>\n\n\n\n

This written statement, together with the statutory notice, are what provides the taxpayer the opportunity to finally challenge the assessment taken against him, though they may be provided to the taxpayer after the fact. <\/p>\n\n\n\n

Administrative Review <\/h2>\n\n\n\n

Under the Internal Revenue Code, within 30 days<\/a> after receipt of the written statement, the taxpayer may request an administrative review from the IRS.\u00a0<\/p>\n\n\n\n

The purpose of the administrative review is to look into the question of whether: <\/p>\n\n\n\n