Code of Federal Regulations Title 26. Internal Revenue § 26.301.7429–2 Review of jeopardy and termination assessment and jeopardy levy procedures

(a) Request for administrative review. Any request for the review of a jeopardy or termination assessment or jeopardy levy provided for by section 7429(a)(2) shall be filed with the district director within 30 days after the statement described in § 301.7429–1 is given to the taxpayer. However, if no statement is given within the 5 day period described in § 301.7429–1, any request for review of the jeopardy or termination assessment or jeopardy levy shall be filed within 35 days after the date such assessment or levy is made. Such request shall be in writing, shall state fully the reasons for the request, and shall be supported by such evidence as will enable the district director to make the redetermination described in section 7429(a)(3).

(b) Administrative review. In determining whether the assessment is reasonable and the amount assessed is appropriate, or whether the jeopardy levy is reasonable, the district director shall take into account not only information available at the time the assessment or jeopardy levy is made but also information which subsequently becomes available.

(c) Abatement of assessment. For rules relating to the abatement of assessments made under sections 6851 and 6861 see §§ 301.6861–1(e), 301.6861–1(f) and 1.6851–1(d) of this chapter.