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CLARKE v. UNITED STATES

Civ. A. No. 82-0664-R.

553 F.Supp. 382 (1983)

Samuel H. CLARKE v. UNITED STATES of America.

United States District Court, E.D. Virginia, Richmond Division.

January 4, 1983.

Attorney(s) appearing for the Case

Sa'ad El-Amin, El-Amin, Palmer & Buchanan, Richmond, Va., for plaintiff.

G. Wingate Grant, Asst. U.S. Atty., Richmond, Va., for defendant.

OPINION

WARRINER, District Judge.

On 8 October 1982 Samuel H. Clarke filed his action under 26 U.S.C. § 7429(b)(1). Clarke filed this action for a statutory review of a termination assessment made by the Internal Revenue Service on 6 August 1982 under the provisions of 26 U.S.C. § 6851.

In general, § 6851 permits the IRS to compute and make termination assessments of income taxes it believes to be due when the government has reason...

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