MEMORANDUM
ALLEN SHARP, District Judge.
Plaintiff Jimmie Lee McGee (taxpayer) entered a plea of guilty to a violation of 21 U.S.C. § 844(a) on April 6, 1973 and was sentenced to one year of imprisonment on May 4, 1973. On October 6, 1972, the Acting District Director of the Internal Revenue Service (IRS) terminated taxpayer's taxable year pursuant to 26 U.S.C. § 6851. The taxpayer was assessed $45,156.54 for the period beginning January 1, 1972...
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