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CLARENDON LTD. v. UNITED STATES

No. 83 Civ. 7235 (RO).

573 F.Supp. 106 (1983)

CLARENDON LTD., Plaintiff, v. UNITED STATES of America, Defendant.

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

October 25, 1983.

Attorney(s) appearing for the Case

Curtis, Mallet-Prevost, Colt & Mosle, New York City, for plaintiff; Peter Fleming, Jr., T. Barry Kingham, William L. Bricker, Jr., Mark H. O'Donoghue, New York City, of counsel.

Rudolph W. Giuliani, U.S. Atty., New York City, for defendant United States; Peter C. Salerno, Richard A. Simpson, Asst. U.S. Attys., New York City, of counsel.

MEMORANDUM AND ORDER

OWEN, District Judge.

Clarendon, Ltd, an international commodities trader founded by Marc Rich, instituted this "summary proceeding" under 26 U.S.C. § 7429 to contest an Internal Revenue Service jeopardy assessment of some $90,000,000 for estimated unpaid taxes, penalties and interest for tax years 1980 and 1981.

There are two issues before me: 1) whether the jeopardy assessment was reasonable under the circumstances, and...

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