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ROGERS v. UNITED STATES

Civ. No. 4-80-250.

511 F.Supp. 82 (1980)

Phillip Morris ROGERS and Phillip Resnick, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, D. Minnesota, Fourth Division.

November 10, 1980.

Attorney(s) appearing for the Case

Louis D. Bass, Minneapolis, Minn., for plaintiffs.

Mary Frances Clark, Tax Division, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM OPINION AND ORDER

DIANA E. MURPHY, District Judge.

Plaintiffs bring this action challenging the reasonableness of a jeopardy termination proceeding brought against plaintiff Rogers by defendant United States, challenging the amount of tax assessed against Rogers in that proceeding, and seeking a ruling that an assignment of certain goods and money from Rogers to plaintiff Resnick has priority over a tax lien filed on those goods and money. Jurisdiction...

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