MEMORANDUM OPINION
JOHN GARRETT PENN, District Judge.
The plaintiffs, in this summary proceeding filed pursuant to the Internal Revenue Code of 1954 (Code), as amended, specifically 26 U.S.C. § 7429(b), seek to have the Court determine the reasonableness of a jeopardy assessment made pursuant to 26 U.S.C. § 6861. The Court has jurisdiction of the proceedings pursuant to 26 U.S.C. § 7429(b) and 28 U.S.C. § 1346(e).
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