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JOHNSON v. C. I. R.

No. 79-172-Civ-J-M.

468 F.Supp. 461 (1979)

Hinton R. JOHNSON, Jr., and Doris L. Johnson, his wife, Plaintiffs, v. COMMISSIONER OF INTERNAL REVENUE and the United States of America, Defendants.

United States District Court, M. D. Florida, Jacksonville Division.

On Motion April 19, 1979.

Attorney(s) appearing for the Case

Fred M. Cone, Jr., Peter W. Mettler, Stephen F. Story, Culverhouse, Tomlinson, Mills, Anderson & Cone, Jacksonville, Fla., for plaintiffs (taxpayer).

Gerald B. Leedom, Tax Div., Dept. of Justice, Washington, D. C., for defendants.

On Motion for Attorney's Fees April 19, 1979.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

MELTON, District Judge.

This cause is before the Court on a complaint filed on February 23, 1979, to determine the reasonableness and appropriateness of a jeopardy assessment imposed upon the plaintiffs by the Internal Revenue Service (hereinafter "the Service") on December 20, 1978. See 26 U.S.C. § 7429(b) (1976). The Service imposed the jeopardy assessment...

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