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McAVOY v. INTERNAL REVENUE SERVICE

No. G 79-266 CA 6.

475 F.Supp. 297 (1979)

Phillip Dwyer McAVOY, Plaintiff, v. INTERNAL REVENUE SERVICE and United States of America, Defendants.

United States District Court, W. D. Michigan.

July 3, 1979.

Attorney(s) appearing for the Case

Lawrence J. Montei, Kalamazoo, Mich., for plaintiff.

James Brady, U. S. Atty., Grand Rapids, Mich., Robert G. Nath, Dept. of Justice, Grand Rapids, Mich., for defendant.

OPINION AND ORDER

MILES, District Judge.

This cause comes before the Court in the form of an action for summary review of a termination assessment made against plaintiff on February 14, 1979. The termination assessment was made pursuant to 26 U.S.C. § 6851 and was in the amount of $107,908 for the taxable year of 1978 and $3,485 for the taxable year of 1979. At plaintiff's request, the Secretary of the Treasury has reviewed the reasonableness of the...

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