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JOHNSON v. UNITED STATES

No. 83 Civ. 6639(MP).

573 F.Supp. 641 (1983)

Gayfryd McNabb JOHNSON, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. New York.

October 28, 1983.

Attorney(s) appearing for the Case

Willkie, Farr & Gallagher by Phillipe Salomon, Anthony Phillips, and Richard Klein, New York City, for plaintiff Gayfryd McNabb Johnson.

Rudolph W. Giuliani, U.S. Atty., S.D.N.Y. by Leona Sharpe, Michael Dolinger, and Frederick Lawrence, New York City, for defendant U.S.

OPINION

MILTON POLLACK, District Judge.

The plaintiff, a taxpayer, sued herein on September 8, 1983 to abate a jeopardy tax assessment which the Internal Revenue Service levied against articles of ladies' jewelry, certain artworks, and other property on June 22, 1983. The abatement was sought pursuant to the special statute governing summary judicial review of jeopardy assessments, 26 U.S.C. § 7429.

The government, on the eve of a hearing at...

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