(h) FINAL DECISIONS OF BOARD. -For the purposes of this chapter the date on which a decision of the Board becomes final shall be determined according to the provisions of section 1140. (i) EXTENSION OF TIME FOR PAYMENT OF DEFICIENCIES.- Where it is shown to the satisfaction of the Commissioner that the payment of a deficiency upon the date prescribed for the payment thereof will result in undue hardship to the donor the Commissioner, under regu- lations prescribed by the Commissioner, with the approval of the Secretary (except where the deficiency is due to negligence, to inten- tional disregard of rules and regulations, or to fraud with intent to evade tax), may grant an extension for the payment of such deficiency or any part thereof for a period not in excess of eighteen months, and, in exceptional cases, for a further 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 sureties, as the Commissioner deems necessary, conditioned upon the payment of the deficiency in accordance with the terms of the extension. (j) ADDRESS FOR NOTICE OF DEFICIENCY.- In the absence of notice to the Commissioner under section 1026 (a) of the existence of a fidu- ciary relationship, notice of a deficiency in respect of a tax imposed by this chapter, if mailed to the donor at his last known address, shall be sufficient for the purposes of this chapter even if such donor is deceased, or is under a legal disability. SEC. 1013. JEOPARDY ASSESSMENTS. (a) AUTHORITY FOR MAKING. -- If the Commissioner believes that the assessment or collection of a deficiency will be jeopardized by 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. (b) DEFICIENCY LETTERS.-If the jeopardy assessment is made be- fore any notice in respect of the tax to which the jeopardy assessment relates has been mailed under section 1012 (a), then the Commissioner shall mail a notice under such subsection within 60 days after the making of the assessment. (c) AMOUNT ASSESSABLE BEFORE DECISION OF BOARD. -The jeopardy 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 1012 (f) prohibiting the determination of addi- tional deficiencies, and whether or not the donor has theretofore filed a petition with the Board of Tax Appeals. The Commissioner may, at any time before the decision of the Board is rendered, abate such assessment, or any unpaid portion thereof, to the extent that he believes the assessment to be excessive in amount. The Commissioner shall notify the Board of the amount of such assessment, or abate- ment, if the petition is filed with the Board before the making of the assessment or is subsequently filed, and the Board shall have jurisdic- tion to redetermine the entire amount of the deficiency and of all amounts assessed at the same time in connection therewith. (d) AMOUNT ASSESSABLE AFTER DECISION OF BOARD. -If the jeop- ardy assessment is made after the decision of the Board is rendered such assessment may be made only in respect of the deficiency deter- mined by the Board in its decision. (e) EXPIRATION OF RIGHT TO ASSESS. -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. (f) BOND TO STAY COLLECTION. - When a jeopardy assessment has been made the donor, within 10 days after notice and demand from the collector for the payment of the amount of the assessment, may 151 GIFT TAX
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