ORDER
JOHN A. REED, Jr., District Judge.
This action was brought by the plaintiff pursuant to Section 7429 of the Internal Revenue Code of 1954 (26 U.S.C.) for judicial review of jeopardy assessments of federal income taxes. The assessments of tax, penalties and interest, in the total amount of $1,001,125.30, were made May 21, 1984, pursuant to Section 6861 of the Internal Revenue Code of 1954. The plaintiff timely requested administrative review (26 U.S...
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