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JEOPARDY ASSESSMENT

Jeopardy assessments are implemented where the assessment or collection of tax is determined to be in jeopardy. Under such circumstances, the IRS is authorized to make an immediate assessment without following the procedures required for an ordinary assessment, and then may proceed to collect the tax as assessed without delay. See I.R.C. sections 6861, 6862. Section 6861 states that:

If the Secretary believes that the assessment or collection of a deficiency . . . will be jeopardized by delay, he shall . . . immediately assess such deficiency . . . and notice and demand shall be made by the Secretary for the payment thereof.

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