Bond to stay assessment and collection upon petition for review

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  • Notwithstanding any provision of law imposing restrictions on the assessment and collection of deficiencies, the review under section 1782 of this title shall not operate as a stay of assessment or collection of any portion of the amount of the deficiency determined by the district court unless a petition for review in respect of such portion is duly filed by the taxpayer, and then only if the taxpayer—
    • (1) on or before the time his petition for review is filed has filed within the district court a bond in a sum fixed by the district court not exceeding double the amount of the portion of the deficiency in respect of which the petition for review is filed, and with surety approved by the district court, conditioned upon the payment of the deficiency as finally determined, together with any interest, additional amounts, or additions to the tax provided for by law, or

    • (2) has filed a jeopardy bond under this Part or the Virgin Islands income tax law.

      If as a result of a waiver of the restrictions on the assessment and collection of a deficiency any part of the amount determined by the district court is paid after the filing of the review bond, such bond shall, at the request of the taxpayer, be proportionately reduced.


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