DECISION AND ORDER
REYNOLDS, Chief Judge.
This is an action brought by the United States to reduce a federal tax assessment against LeRoy Doyle ("taxpayer") to judgment and to enforce a corresponding federal tax lien against certain property owned by the taxpayer. The taxpayer has counterclaimed for a determination of the reasonableness of the assessment pursuant to the statutory procedure set out in 26 U.S.C. § 7429. Currently before the court are...
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