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CHEEK v. UNITED STATES

Nos. ST-C-84-92 to ST-C-84-94.

587 F.Supp. 1012 (1984)

Garvey Martin CHEEK and Judy Cheek, Plaintiffs, v. The UNITED STATES of America, Defendant. Garvey M. CHEEK, Plaintiff, v. The UNITED STATES of America, Defendant. Judy CHEEK, Plaintiff, v. The UNITED STATES of America, Defendant.

United States District Court, W.D. North Carolina, Statesville Division.

July 12, 1984.

Attorney(s) appearing for the Case

Herman Wolff, Jr., Wolff & Martin, Raleigh, N.C., and J. Gary Vannoy, Vannoy, Moore & Colvard, North Wilkesboro, N.C., for plaintiffs.

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., and Steven Shapiro, Chief, Civ. Trial Sec., Southern Region, U.S. Dept. of Justice, Washington, D.C., for defendant.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

McMILLAN, District Judge.

These three civil actions were brought by the plaintiffs pursuant to 26 U.S.C. § 7429 to review jeopardy assessments made by the Internal Revenue Service. A hearing was conducted on June 19, 1984. The court, having considered all the pleadings, memoranda, evidence, and arguments of counsel, makes the following

FINDINGS OF FACT

1. On March 9, 1984, jeopardy assessments...

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