§ 10111. Payment and collection of deficiencies and assessments; jeopardy notices (a) Upon notification to a taxpayer of any deficiency, or upon assessment against the taxpayer of any penalty or interest, under section 10106 of this title, the amount of the deficiency or assessment shall be payable forthwith and shall be collectible by the Commissioner 30 days after the date of the notification or assessment; provided, however, that if a taxpayer timely appeals a notice or assessment, the amount of the deficiency or assessment shall be collectible 30 days after the Commissioner gives notice of the determination of the appeal or, if the taxpayer appeals to the court, on the date the appeal becomes final. (b) Notwithstanding subsection (a) of this section, if the Commissioner believes that collection of any tax liability is in jeopardy, the Commissioner may demand, in writing, that the taxpayer pay the tax at once. The demand may be made concurrently with, or after, a notice of deficiency or assessment of penalty or interest is given to the taxpayer under section 10106 of this title. The amount of the tax shall be collectible by the Commissioner on the date of the demand unless the taxpayer files with the Commissioner a bond in an amount equal to the deficiency, penalty, or interest sought to be collected as security for such amount as finally may be determined.
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