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72d CONGRESS . SESS . I. CH. 209 . JUNE 6, 1932 . onn TAXES
excess of eighteen months, and, in exceptional cases, for a further Bond req uire d . period not in excess of twelve months . If an extension is granted,. the Commissioner may require the donor to furnish a bond in such amount, not exceeding double the amount of the deficiency, and with such sure ties , as the G'o mmis sion er d eems nec essa ry, cond itio ned upon the payment of the deficiency in accordance with the terms of the extension . Notice to last known (j) ADDRESS FOR NOTICE OF DEFICIENCY .-In the absence of notice add ress . Post, p.257.
to the Comm issioner under section 527(a) of the existence ofa fiduc iary rel atio nshi p, n otic e of a deficiency in respect of a tax imposed by this title, if mailed to the donor at his last known address, shall be sufficient for the purposes of this title even if such don or is deceased, or is under a legal disability . Jeopardy assess- SEC. 514. JEOP ARDY A SSESSM ENTS . menu. Immediatelyassessed (a) AUTHORITY FOR MAKING .-If the Commissioner believes that iy delay . t ion jeop ardi zed by
the assessment or collection of a deficiency will be
b jeo pard ized y delay, he shall immediately assess such deficiency (together with all interest, additional amounts, or additions to the tax provided for by law) and notice and demand shall be made by the collector for the payment thereof . De acfeneyletters,
h DEFI CIENC Y LETTERS.-If the jeopardy assessment is made Notice to be mailed . () before any notice in respect of the tax to which the jeopardy assess- ment relates has been mailed under section 513(a), then the Com- missioner shall mail a notice under such subsection within 60 days after the making of the assessment . Amount assessable (c) AMOUNT ASSESSABLE BEFORE DECISION OF BOARD .-The jeop- before Board's decision . ardy assessment may be made in respect of a deficiency greater or less than that notice of which has been mailed to the donor, despite the provisions of section 513(f) prohibiting the determination of additional deficiencies, and whether or not the donor has theretofore Redetermination. filed a petition with the Board of Tax Appeals . The Commissioner shall notify the Board of the amount of such assessment, if the peti- tion is filed with the Board before the making of the assessment or is subsequently filed, and the Board shall have jurisdiction to redetermine the entire amount of the deficiency and of all amo unts assessed at the same time in connection therewith . Amount assessable
d) AMOUNT ASSESSABLE AFTER DECISION OF BOARD .-If j after decision of Board. ( the eo pard y as sess ment is made after the decision of the Board is rendered such assessment may be made only in respect of the defi- ciency determined by RIGH T Board in its decision . nal Not decision, al lowe d etc . 5-
(e) EXPIRATION O F RIGH T To AS SES S .-A jeopardy assessment may . not be made after the decision of the Board has become final or after the donor has filed a petition for review of the decision of the Board . Bond to stay col lec- (f) BOND TO STAY COLLECTION .-When a jeopardy asse ssme nt h as tIon. been made the donor, within 10 days after notice and demand from the collector for the payment of the amount of the assessment, may obtain a stay of collection of the whole or any part of the amount of the assessment by filing with the collector a bond in such amount, not exceeding double the amount as to which the stay is desired, and Conditions. with such sureties, as the collector deems necessary, conditioned upon the payment of so much of the amount, the collection of which is stayed by the bond, as is not abated by a decision of the Board which has become final, to ether with interest the reon as prov ided in Pot, p .255.
section 523 or 524(b) (4) . if bond Further given befo ro conditions, conditions, (g) SAME -FUR THER CONDITIONS :If the bond is given before the filing petition . donor has filed his petition with the Board under section 513 (a), the bond shall contain a further condition that if a petition is not filed within the period provided in such subsection, then the amount the
