Code of Federal Regulations Title 27. Alcohol, Tobacco Products and Firearms § 27.70.210 Review of jeopardy assessment or levy procedures;  judicial action

(a) Time for bringing judicial action. An action for judicial review described in 26 U.S.C. 7429(b) may be instituted by the taxpayer during the period beginning on the earlier of:

(b) Extension of the period for judicial review. The U.S. Government may not seek an extension of the 20–day period described in 26 U.S.C. 7429(b)(2), but it may join with the taxpayer in seeking such an extension.