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BERKERY v. UNITED STATES

Civ. A. No. 82-862.

544 F.Supp. 1 (1982)

John BERKERY v. UNITED STATES of America.

United States District Court, E. D. Pennsylvania.

April 22, 1982.

Attorney(s) appearing for the Case

Thomas W. Ostrander, Philadelphia, Pa., for plaintiff.

Will E. McLeod, Atty., Tax Div., Dept. of Justice, Washington, D. C., for U. S.

OPINION

LUONGO, Chief Judge.

On or before December 14, 1981, James T. Rideoutte, District Director of Internal Revenue for Philadelphia, made a termination assessment of federal income tax liability against plaintiff, John Berkery, pursuant to 26 U.S.C. § 6851(a)(1).1 Plaintiff now brings this civil action pursuant to 26 U.S.C. § 7429 seeking judicial review and abatement...

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